Code 410(a)

Is adjunct professionals a reasonable exclusion from Code 410(a)??

Pardon my ignorance, can you provide more information?

I think you mean 410(b). 410(a) is the "no cost" exclusions, i.e. union if plan was subject of bargaining, NRA's with no U.S. source income, etc. I think what you are asking is whether "adjunct professionals" would be excludable, even if not listed in 410(a), if without them your plan still meets 410(b).

Generally, the answer is yes, provided that this is a bona fide employee distinction established in your employee handbook, etc., and employees know when they are classified as one or the other, so check the HR infrastructure you have for the classification. It can't just be words you stick in the plan document and then the plan administrator arbitrarily decides who is one.