Entry date calculation

I want to see if there is agreement of my understanding of the Regulations on this situation.

I have always understood that the regulations with respect to eligibility/entry dates are designed so that basically if a person must work 1 year/age 21, then the entry dates must be set in such a way that ultimately the person is not required to work more than 18 months before he enters the plan.  So a plan with a 1-year requirement and quarterly entry dates is fine, because no way would someone have to work more than 18 months before entering the plan.

HOWEVER, in looking more closely at the regs, they require that the person must enter by the earlier of:

• the 1st day of the plan year after meeting the 1 year/age 21 requirement OR
• 6 months after meeting the 1 year/age 21 requirement.

I am thinking this essentially requires every plan to use the first day of the plan year as an entry date, but I want to see if that is correct. 

We have a calendar year plan that wants to use entry dates of 2/1, 5/1, 8/1 and 11/1 to coincide with open enrollment for other benefits.  I think they MUST also use a 1/1 entry date.  EXAMPLE:  a person hired 11/15/18 works one year by 11/15/19, he must enter on 1/1/20, he can't wait until 2/1/20.  I initially thought the 2/1 entry date was fine because the person would be entering with 18 months of hire, but I think in this case, he must enter 1/1.

Agreed?  Any other thoughts?  Thanks!

agree