I have a client that was on a pre-approved VS plan effective 1 August 2003. Subsequently they changed administrators and went to another pre-approved VS plan effective 1 April 2005. Can they be a "prior adopter" since they had adopted a pre-approved plan prior to 17 February 2005? I don't think they can use the 6-year cycle by signing an 8905 because the requirements for an "intended adopter" require the employer to have a qualified individually designed plan. Any thoughts?

Off the cuff, I think they are a prior adopter if there was not a gap of time after going off the old VS and onto the new one.

Thanks for the replay. That's what I was thinking also. Of course I can't find anything "official" to substantiate it.