Gateway required?

Brain cramp - PS has 1 YOS/1,000 eligibility. SH nonelective is provided to anyone eligible to defer, which is everyone. If someone has never worked 1,000 hours, does the fact that they receive 3% nonelective require that they receive gateway? I'm saying no, but second-guessing myself...

P.S. - my thinking for "no" is that they can be disaggregated as statutorily excludable.

[redacted]

how about 'maybe'

my understanding if you test otherwise excludables separately, this group could be tested on an allocation basis and therefore not need the gateway

Right, so they get 3% SH, but no gateway. That's what I was thinking, but this is a confusing subject...

with a DC plan, to get to get to the magical land of cross testing, you have to pass through the gateway.

if you are testing on an allocation basis you are not trying to reach cross testing land so you have no gateway to pass through.  (And just because you are taking a lunch break at that place with a clown, the golden arch is not the same as a gateway)

The thrill of dual eligibility....  the agony of brain cramps!

Your document probably allows you to disaggregate, and it's likely a plan administrator choice. So if the under 21/1 group could help your results by including them in the cross-testing, you could bring them all in to the test and they all get the minimum gateway. If that does not produce better results, they can disaggregated, and as Tom indicated, they are part of their own test (likely on a contributions basis which requires no gateway).

Thanks all. This confirms my thinking - the logical process just wasn't crystalizing well that morning. One of those days when you question what you know (or think you know)...

It is a big help to have these boards to have people either agree, or inform you that you are crazy, and more importantly, to explain WHY you are or are not crazy.

Is tax season ever going to end??? I'm ready for a break!!!