QNEC in testing

Hello all, Had a client that didn't start an employee's deferral on time back in 2018. Since the missed contributions cross two plan years, how are the QNEC, missed match, and earnings  tracked in testing with the 2018 testing being completed already. The entire correction is being made in 2019. 

Also just wanted to clarify that the missed match goes in as match source and not a QMAC since it's corrective. Thanks! 

The document may state how to use QNECs. For instance, ours states to only use them to the extent necessary to pass the ADP test. 

You are correct RE: Match source. 

Is there a specific question? Is it how are the contributions shown in 2019 if the correction relates to earlier plan years?

From the EPCRS Rev. Proc 2019-19

1. An employee with a missed opportunity to defer is not included in the ADP / ACP tests. You run the tests without them, THEN do the MOD correction. 
Page 79: "For purposes of this section .05(2), in order to determine whether the plan passed the ADP or ACP test, the plan may rely on a test performed with respect to those eligible employees who were provided with the opportunity to make elective deferrals or after-tax employee contributions and receive an allocation of employer matching contributions, in accordance with the terms of the plan, and may disregard the employees who were improperly excluded."

2. The correction for the missed match is deposited as QNEC- Not Match. Yes, this will affect the vesting that would have applied, as QNEC is 100% vested.  

Page 76: "The corrective employer nonelective contribution is equal to the matching contribution the employee would have received had the employee made a deferral equal to the missed deferral determined under section .05(2)(b)." 

3. The corrective contribution is generally related to the year of correction - not necessarily the year of the failure (at least for a MOD failure)

P. 27 - tax liability for a closed year is not redetermined because of correction
P. 30 - for allocation errors (which this is not, but if it were) the correction would count as an annual addition for the year of failure. 

My experience is that QNEC for a MOD failure doesn't count toward any participant limits, but I can't find a citation for it. I'm sure there are other threads on the message boards.