A client is interested in providing QSERP benefits for former HCEs covered under a nonqualified SERP. There is not too much guidance in the regs regarding coverage and nondiscrimination testing for former employees. It states that many of the tests applicable to actives will apply to former employees. I'm assuming that for the general test, annual accrual rates can be determined by taking accrued or pensions in pay and dividing by credited service and then proceding as usual. Any thoughts or suggestions?