HCE requests full distribution but plan always fails ADP

I am wondering how to handle this situation.

HCE retires and is requesting a rollover of 100% of his account balance.

The document states that distributions are paid out: immediately

The plan fails the ADP test every year and he is due a refund.

Should the plan pay out all of his account, except for current year contributions?  or do we hold until after the APD test is completed next year?

Thank you!

Is he planning on rolling over the funds?

yes, he has requested to rollover 100%.

I think you let him take the whole thing to his rollover, but warn him up front that some of that amount is going to be deemed an ineligible rollover contribution and will be reflected as such on the separate 1099-Rs.  If he wants to avoid the hassle he can wait, but it's his call.

(And the fact he will have to withdraw full the corresponding amount of funds (plus earnings) from his IRA account and an ineligible contribution.