We have many small locations (with less than 50 employees) across two bordering states and have typically rolled up all of our locations into a single, regional AAP under our headquarters. Our HQ is the only establishment we have with 50+ employees, and all locations ultimately report into an official at HQ.

We also have a single location in a third state, located in a different region. A separate AAP is kept for this location. Recently, we have expanded in this state and the AAP will go from covering 1 location and 10 employees, to 6 locations and about 100 (but no location has 50+ employees). Previously, it was easy to keep this plan separate because we did not need to roll the employees up under the HQ plan, as they did not report to a manager in the HQ plan. With the expansion however, we now have many employees reporting to someone at HQ that could roll up into the HQ plan.

May we continue to maintain regional AAPs, or are we required to roll up these employees into the HQ plan?

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