Despite prodding as well as disclosure of what has to happen, there are just going to be some (calendar plan year) clients who just are unable to get census in time to certify the AFTAP by April 1. Surprise!

So, supposed the 2007 AFTAP is certified as 85%. Then, the presumtive 2008 AFTAP effective April 1 is 75% and restrictions apply. The Plan must provide notice of the restrictions to some persons (see my most recent post) by the end of April. Suppose the client gets information in time to certify the 2008 AFTAP by April 20. Must Participant still be give notice?

In short, is the effective deadline for certifying the AFTAP April 30?