Minimum Coverage Testing

We have just taken over a 401(k) plan with a safe harbor match. The plan's eligibility has no age or service requirement. Union employees as well as part time employees as a class are excluded.. In previous years, the plan has failed the minimum coverage tests.

Now, for 2025, the client wants to change the eligibility to 3 months and 250 hours of service beginning 10/01/2025. Anyone hired on or after that date would be subject to the new eligibility. 

They are looking for ways this late in the year to avoid failing the minimum coverage test for 2025. I don't think the above is feasible and would help.

Any insights would be appreciated.

They failing even when testing otherwise excludable separately?

That's without getting into the question of whether or not "part-time" is a reasonable classification for exclusion.

I was also questioning how they failed. we are just taking over this plan for 2025. ADP hasn't released the testing results to us yet so I have nothing to show you. I am only going on what my boss said to me yesterday. Apparently there are many part timers who only work a few weekends a year as it's a theater group.

I will gladly share the number when I get them.

Thank you!

Perhaps they mean that the group receiving the safe harbor match fails 410?  Too few contributing 401(k) to receive a match and the contributors include HCEs.

Coverage testing isn't hurt because an eligible person contributed 0 and got no match specifically because the match calculates to zero, though.

Does anyone here actually like ADP?