5500 COunt - Term with zero beg balance

I have a plan that was audit level in 2021.  They are current at 101 participants.  Two participants terminated in 2021  has a zero balance on 1/1/2022, but received lost earnings within the year.  Datair is counting them in the 2022 beginning participant count.  Since they didn't have a beginning balance, should they considered a participant for the Form 5500 count?

Might it be that some record or system treats those participants’ accounts as having an investment receivable on the last day of 2021 and on the first day of 2022?

Terminated participants in a prior year with no beginning balance as of the current year are NOT participants as of the beginning of the current year.  In the situation you describe, as I understand it, 2021 terms with no balance as of 1/1/2022 are not participants as of 1/1/2022.  Seems to me Datair is counting them incorrectly.  The part that throws me a bit is your comment "received lost earnings within the year."  I assume you are referring to 2021 activity... with no beginning balance as of 1/1/22 I don't see how they could have shared in any earnings/losses in 2022, as there is $0 basis. 

"Lost earnings" to me sounds like a late deposit from a prior year corrected in 2022.  If they terminated in 2021 and took a full distribution before the end of 2021, and late deposit earnings were made after 1/1/2022, I would not count them in the 1/1/2022 beginning count.

As a DATAIR user, perhaps the lost earnings allocation made in 2022 is coded as happening as of 1/1/2022. If TinaW changes the allocation date of the lost earnings to something later in 2022, I think (but cannot say for certain) that it would drop the BOY count to 99, thus getting out of the audit for 2022.