my client has a ps plan-he is 100% owner. his two sons are in school to become dentists and also working at the practice. they just became age 21 in and are eligible to participate in the plan. they are considered hce's because of attribution and are completely throwing off my testing (super integrated plan). i don't necessarily want to do an election not to participate because one or both may come to work at father's practice once they graduate. what to do?

thanks for any help...

How about amending the plan document to exclude all HCEs who are HCEs solely as a result of attribution?

or simply define your classes as:

1. owners not by attribution
2. owners by attribution
3. all others