"Plan had 103 participants at 12/31/2019. Eligibility is 1 year of service, for deferrals enter on 1/1 or 7/1 following meeting eligibility requirements. Profit Sharing is one year and enter on 1/1 preceding meeting eligibility.

At 12/31/2019 there were 103 participants. As of 1/1/2020 there were 14 additional participants eligible for the deferral portion of the plan bringing the total to 117, still under 120 to require an audit... BUT there were 12 additional participants that became eligible for the profit sharing portion on 1/1/2020 as well but not eligible for the deferral part of the plan. (So hired 2nd half of 2019.)

So counting them the total at beginning of year is 129 and would require an audit for 2020. I'm fairly certain those employees all must be counted in the beginning-of-year count, but is there any way not to count them because at 1/1/2020 they were technically not eligible yet and didn't become eligible until they had their 12 months of service for eligibility? For example, if date of hire is 12/01/2019 and had 1 year 12/01/2020, date of participation for Profit Sharing is 1/1/2020."