The term 'highly compensated employee' is defined by the federal government:
Here's the likely definition - its the same one used to decide how employees are handled with regard to retirement and pension plans.
"Highly compensated employee. A highly compensated employee is an individual who:
Owned more than 5% of the interest in your business at any time during the year or the preceding year, regardless of how much compensation that person earned or received, or
For the preceding year, received compensation from you of more than $110,000 (if the preceding year is 2010 or 2011, $115,00 if the preceding year is 2012) and, if you so choose, was in the top 20% of employees when ranked by compensation."
So, even if you hit the $ limit - you must be in the top 20% to be considered Highly Compensated.