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Kentucky Trust Company
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| Different Eligibility Conditions for HCEs -- Discriminatory? BenefitsLink Message Boards  Feb. 8, 2021 "I am working with a doctors' office and their 401k plan. They currently have a one year of service/1000 hours eligibility requirement to enter the plan. However, they would like to change that to a 6 months elapsed time requirement for new doctor hires. The new doctors would not be owners. If the new doctors make less than $130,000 (2021) and are not HCEs in their first year employment, then there would not be a discrimination issue for 2021, is that correct? What if, in future years, their earnings are above the HCE dollar threshold? Is that something that could be viewed as discriminatory a year or two after they are hired? I would not think so because I think any eligibility discrimination would be applied in the year of hire. But I wanted to check if others agree." |
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