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Historical Data for different time period than your employee snapshot data

Anonymous - July 17, 2017
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I was always taught that you run an AAP by selecting the snapshot date and then pulling the historical actions for 1 year back from that date. I can find no legal or regulatory item outlining that the snapshot date and historical year must match up this way.

Can a Company have a snapshot date of, say, January 1, 2017 for example and have their historical dates be April 1, 2016 through March 30, 2017 rather than the traditional January 1, 2016 through December 31, 2016. This means the Year End monitoring or Q4 would not be completed until 3 months after the snapshot date. This seems wrong to me but I can find no regulatory reason that would not allow this. I might also add that the narrative date (AKA “Plan Date”) is April 1, 2017.

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