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Posted

Participant does not qualify for a PS (term < 500 hrs).  However, plan fails ADP and he's getting a QNEC in lieu of HCE distributions.

Does that QNEC trigger a gateway?

QKA, QPA, CPC, ERPA

Two wrongs don't make a right, but three rights make a left.

Posted

So, if it's in the Gateway, is it in the general testing?  I thought I read somewhere that ADP QNECs are included..

QKA, QPA, CPC, ERPA

Two wrongs don't make a right, but three rights make a left.

Posted

As I recall, a plan has to pass testing with and without the QNEC. I guess you can't cheat on the original allocation. normally HCEs don't receive QNECs so passing with a QNEC is less of a problem.

A gateway is required only if you cross test the allocation. (I don't think simply running the avg ben pct test triggers a gateway)

but if you can pass testing on an allocation basis then no gateway

 

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