In determining the previously excluded contributions component of the exclusion allowance, are SEP, SARSEP and/or SIMPLE contributions included? Neither the regs nor the final audit guidelines specifically cross-refer to them. Although a tax-exempt cannot maintain a SARSEP, a for-profit educational operation could have maintained one and then elected to go not for profit, qualified under 501©(3) and adopted a 403(B). As for the SIMPLE, the Code requires that it be the only plan. An employer could have adopted the SIMPLE, frozen it and then adopted the 403(B).

Does anyone have any thoughts on whether these contributions are part of the previously excluded contributions component of the exclusion allowance?

If they are contributions to a qualified plan by the same employer, then I think they are. The audit guidelines and regs under 403(B) define prior years deferrals to include contributions to a qualified plan of the employer.