Mr Bagwell Posted June 19, 2019 Posted June 19, 2019 I have a plan that has quarterly entry for participation. (no age requirement) The plan excludes Part -time, Temporary, and Seasonal employees. In the Corbel document, 1,000 hours of service was used to describe the PT, temp, and seasonal employee. Here is my dilemma, because the plan has only the Qtrly entry requirement, the Subsequent eligibility Computation Period was not completed. Plan year and Anniversary year are the common choices. If an excluded employee would happen to not work the 1000 hours for the next year, that's fine, they would not become eligible. But what subsequent eligibility comp period do I track next? I cannot find anything in the master plan to default to plan year or anniversary year. The plan needs to choose plan year or anniversary. Am I missing another provision in the document that might clear this up?
Mr Bagwell Posted June 20, 2019 Author Posted June 20, 2019 I'm pushing this back to the top of the list to see if anyone has any thoughts on this. Thanks
Lou S. Posted June 20, 2019 Posted June 20, 2019 Have you read 1.88 of the Master Text? I believe the answer is there in conjunction with how the AA was completed in the "Eligibility Requirements" Section. Also have you tried posing the question to Corbel/FIS directly, I found they are usually very good about giving responses concerning their document. Belgarath 1
Mr Bagwell Posted June 21, 2019 Author Posted June 21, 2019 Thanks for the comments Lou. The Master Text I reference doesn't have a 1.88, just goes to 1.71. I did pose the question to Corbel/FIS. They referenced me to the Change in Employment Status section. I didn't find that answer to be helpful. Here is the wording for the section Part-Time/Temporary/Seasonal Employees. See Section 1.22(D)(4). A Part-Time, Temporary or Seasonal Employee is an Employee whose regularly scheduled Service is less than 1,000 (specify a maximum of 1,000) Hours of Service in the relevant Eligibility Computation Period. [Note: The "relevant" Eligibility Computation Period is the Initial or Subsequent Eligibility Computation Period as defined in Section 2.02(C).] Underlined emphasis mine. 2.02(C) goes on to say, the Plan measures Subsequent Eligibility Computation Periods in accordance with the Employer's election in its Adoption Agreement. I think I am in a rock and a hard place. I can get the future fixed. Not sure how to get the past resolved.
Lou S. Posted June 21, 2019 Posted June 21, 2019 I think if it's unclear in the document the Plan Adimistrator would resolve in most favorable way to participant which would be 1st day of the quarter following anniversary in the 12 month period where they worked 1,000. If the document cleary switches to Plan year after the first computation period then they would enter first day of the next plan year. As for the 1.88 MT that was referenced in my AA, your AA may reference a different MT section.
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