For our 401(k) plan minimum coverage testing, we do snapshot testing and a three-year testing cycle, per rev. proc. 93-42.
Does the new Schedule R's part IV, that requires you to answer how you passed your minimum coverage test (ratio percentage v average benefit), mean that you can't use a three-year testing cycle any more? The instructions say that the three year testing cycle no longer provides an exception to filing the schedule as it did with the former Schedule T that contained all the minimum coverage testing information. But can you file the new Schedule R and mark "ratio percentage" in a year in which you didn't actually conduct the test? Or does the new form effectively repeal the three-year testing cycle option? This result doesn't make a lot of sense to me - I'm inclined to stick with the three-year cycle and check the box for the test that was originally passed - but I think the form's instructions aren't entirely clear.