"Plan document has 6-month wait to enter the plan. No minimum hours of service requirement -- just elapsed time. This pulled in several part-time employees who work fewer than 1000 hours. They have no balance in the plan. The participant count went over 120 as of 1/1/2020 and so the plan will need an audit for 2020.

Effective 1/1/2021, the plan has been amended to exclude part-time, seasonal and temporary employees, defined as those scheduled to work less than 1,000 hours. The intent is to exclude these employees prospectively from participation as of 1/1/2021 -- i.e., they will no longer be covered under the plan and thus not will not be included in the participant count.

Example: an employee who always worked less than 1,000 hours was eligible in 2020 and has no plan balance. The 2021 amendment excludes that employee from participation in the plan effective 1/1/2021.

I think this works. Comments?"