FAQ 866: HCE-- Top Paid Group determination with doctors hired on the same day


We have a new plan with 3 doctors all hired the same day, making the same salary, etc. The plan is using the Top Paid group to determine HCE's and the employee count is 10. ASC is picking 2 of the three doctors as HCE's for next year. However we are trying to determine how ASC picks who is the HCE when all things are the same. The plan is using New Comp. for PS and we would like the youngest doctor to be the NHCE if possible, however ASC is actually picking the oldest doctor as the NHCE.


1. The system will use the date of hire, with the earlier date of hire being considered first. Age makes no difference.
2. If their compensation and dates of hire are the same, then it would probably depend on the sorted order (the first participant read would get priority.