A single employer maintains 2 separate plans:
1) 401(k) with match
2) New Comparability Profit Sharing

Both plans pass 410(B) on their own. Both plans cover the same employee group.

Is it necessary to include deferrals and match in 401(a)(4) testing for the New Comp. plan?

Thanks.

For purposes of the average benefits percentage test ALL OTHER PLANS are included even if the other plans satisfy coverage under the ratio percentage test. see 1.410(B)-7(e)(1). This even includes ESOPs. About the only exception is union and QSLOBs. and when aggregating, you can only impute permitted disparity on one of the plans, and of course never on the ESOP.
and if one plan is a DB and the other a DC, you may test separately.

[This message has been edited by Tom Poje (edited 12-07-1999).]

One caveat, you don't aggregate them in determining the equivalent benefit accrual rate for each employee.