HCE determination based on indexed salary

Looking into a new plan. The first plan year will be from 7/1/19 to 6/30/20, same as corporate fiscal year.

One employee is in question with the following salaries

7/1/18 to 7/1/19 109k

Calendar 2018 105k

Calendar 2019 126k

7/1/19 to 6/30/20 125k+ or 130k+

Using lookback, looks like non-HCE for plan year beginning 7/1/19, agree? Is there anyway I can make the employee HCE for plan year beginning 7/1/19.

Also, to determine the HCE status for plan year beginning 7/1/2020, his salary has to be at least 125k+ as of 6/30/2020, agree? Or had to be as 12/31/19?

Thank you

Does the plan provide for the calendar year data election?

Plan not set up yet and trying to determine the best way to accomplish this.

Following up to see if my understanding is correct after reading EOB with examples. The compensation used for determining the threshold is for the calendar year and not fiscal year. I now understand the question from C.B. Zeller. First time dealing with a situation like this so did some serious reading.

Going back to my previous example with some changes:

Brand new plan year, effective 7/1/2019 with PYE 6/30/2020.

Calendar 2018 108k

Calendar 2019 120k

Calendar 2020 131k

If indexed amount - non-HCE till plan year beginning 7/1/2021 - correct?

If calendar year election made, HCE for plan year beginning 7/1/2020 - correct?

Thank you