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Posted

Here is the plan information:

Plan has a prevailing wage contribution that is NOT an offset contribution, but a straight QNEC.

Plan also has a 4% PS contribution:  It excludes participants who "receive" the PW contribution from the Profit Sharing.  In reality, they excluded all hourly employees from the PS contribution. 

Of course, the plan does not pass coverage testing on the ratio basis.  Additionally, I believe the plan needs rate group testing as they have different levels of ER contribution.    

Question:  Can the plan be tested on an accural rate for the ABPT for coverage, then on an allocation basis for the rate group testing?

 

Posted

Yes, the plan can test the average benefits test on a benefits basis and test the rate groups on a contribution basis (no gateway required). Or vice versa (gateway required). All nonelectives, including the prevailing wage QNEC, are lumped together for coverage and nondiscrimination. FYI. 

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