Company X maintainis Plan M, a 401(k) plan providing matching contributions on elective deferrals and/or matching contributions. Employee A was participating in Plan M, making after-tax contributions and receiving matching contributions during 2001. During the beginning of 2002, A goes on short-term disability and is not able to have his/her contributions continue to Plan M. A returns to work in August, 2002. Although Plan M's procedures provide for the reinstatement of the contributio elections of employees on short-term disability or a leave of absence upon reemployment, A was not able to contribute to Plan M until January, 2003. The issue is, how can the plan make up for the missed after-tax contributions for the period of August through December, 2002?
In Rev. Proc. 2002-47, there is a deemed safe harbor correction method for eligible employees who are excluded from participation. However, none of the examples in the appendix to the Rev. Proc. address the appropriate method of correcting missed after-tax contributions. Therefore, anyone's thoughts on this matter would be sincerely appreciated.