Eligibility - When does a Participant Enter

Eligibility is 18 and 1 year of service - immediate entry date

Computation period changes to Plan Year if service is not met during the initial computation period ( date hire to date of hire).

Hired 4/1/2017

As of 3/31/2018 - employee did not complete 1,000

Moves to Plan Year 1/1/2018 - 12/31/2018

Question - as of 7/10/2018 employee completed 1,000 hours, does the employee enter 7/10/2018 or does he wait until the close of the 2018 year end and enter on 1/1/2019.

Does the determination of the 1,000 hours get done after 12/31 or when they are actually met?

Thanks

I am assuming since you didn't bring up age this person is 18 or older the whole time.

The requirement is 18 AND 1 YOS. 

Based on what you said this person had the 1 YOS on 12/31/2018.  The only date you really could argue about with immediate DOE is 12/31/2018 vs 1/1/2019 in my mind.   The intent was most likely 1/1/2019 but intent and document aren't always the same. 

That debate could be cleared up by looking at the definition of Date of Entry.  Does it say you enter upon meeting the requirements "immediate on or next following" or "next following" DOE?  Hope the document isn't sloppy on this point. 

But this person doesn't have 1 YOS on 7/10/2018 so that date is out.  

I would argue that the computation period is not over (and the EE has not accrued a YOS) until the last day in the period is over. Entry 1/1/2019.  

I've seen a document that says the entry date is the day on which the 1 year of service requirement is satisfied.  With this definition, 12/31/18 would be  the entry date.  Other documents say the first day of the month next following.  Still other documents say first day of the month coincident with or next following.  Hopefully the document is very clear on this point.

I'm not sure if I ever saw a document with an entry date as the day following the service requirement.

And the answer is ... What does the plan say?

Our VS document has a default provision for using a year of service for eligibility that credits the year of service at the end of the eligibility computation period.  There is an optional provision that credits the year of service when the participant completes 1,000 hours.  Without seeing the plan document, all we can do is guess. 

3 hours ago, chc93 said:

I'm not sure if I ever saw a document with an entry date as the day following the service requirement.

That is interesting.

Here would be an example of it by the way.   This is from one of the plans I work on. 

An Eligible Employee shall become a Participant as of the first day of
the month next following the date the Employee met the eligibility requirements of
Section 3.1,

We had a person who was hired 3/2/2017.  It is a 1 year and 1,000 plan.   They had the 1,000 hours met by 3/1/2018.  In most plans it is clear you would enter on 3/1/2018 but this one it seems rather clear they enter on 4/1/2018.  

So, I really think the answer to the original question is in the document.   I have seen the provision Kevin talks about entering once you hit 1,000 hours but I would never describe it has 1,000 hours and 1 YOS provision.  

But the guy who taught me this business stressed over and over 99% of all questions can be answered in the document.  

I agree with your example.  But if the document said the first day of the month coincident with or next following, then wouldn't the entry date be 03/01/2018, since he would have met the 1000 hours by 03/01/2018.

In the document I mentioned, the entry date was the day on which the 1 year was satisfied.  What I haven't seen is the entry date being the day after the day on which the 1 year was satisfied.  Example.... hired 03/10/2018.  By the document I mentioned, entry date would be 03/09/2018.  But if the day after the day on which the 1 year was satisfied, then entry date would 03/10/2018 (no first day of month provision).

Anyway... thanks for the discussion.

19 hours ago, chc93 said:

I agree with your example.  But if the document said the first day of the month coincident with or next following, then wouldn't the entry date be 03/01/2018, since he would have met the 1000 hours by 03/01/2018.

Anyway... thanks for the discussion.

I agree

That is why I asked which kind of language the op has in that document.  The answer here really could hang on a pretty subtle bit of wording regarding entry in a document.  

the following, from a document

if (ii) is checked then you need the 1000 hours in a 12 month period. if not completed, as indicated above you now have to complete 1000 from 1/1/2018 - 12/31/2018 and enter the date following.

(based on the next section of the document). if it is solely 1000 hours then you would have checked (iv) that indicates the requirement is met once the hours requirement is met.

you still have a 12 month period to avoid someone having 600 hours in 12 months but keeping the clock running, waiting for that 1000th hour to be completed.

10.  Service Requirement for Elective Deferrals

a.     Minimum service requirement for Elective Deferrals/Voluntary Contributions:

i.      [  ] None

ii.    [  ] Completion of one Year of Eligibility Service - Hours of Service necessary for a Year of Eligibility Service: 1000 (not to exceed 1,000)

iii.   [  ] Completion of one Year of Eligibility Service - elapsed time

iv.    [  ] Completion of            Hours of Service (not to exceed 1,000) within a twelve month period. The service requirement shall be deemed met at the time the specified number of Hours of Service are completed

v.     [  ] Completion of            months of service - elapsed time (not to exceed 12)

vi.    [  ] Completion of            Hours of Service (not to exceed 1,000) in a            month period (not to exceed 12 - hours of service failsafe applies)

vii.   [  ] Completion of            consecutive months of continuous service (not to exceed 12 - hours of service failsafe applies)

viii.         [  ] Other:            (hours of service failsafe applies if elapsed time is not specified