Is a person an active participant in an employer-sponsored retirement plan if he or she was only active for a short time?
Yes. An individual is considered an active participant even if his or her participation in the plan has been for only a short period.
It is the actual credit to the retirement plan that results in the active status, not necessarily the duration of the participation.
(For more, read Are You an Active Participant?)
This question was answered by Denise Appleby.