is a codification of three separate programs that the IRS makes available for correcting plan mistakes:
Under the old EPCRS
rules, correction of these failures entailed making a qualified nonelective contribution (QNEC) on behalf of the employee affected by the mistake.
This violation is not directly addressed in the EPCRS
A 403(b) plan sponsor may use the Voluntary Correction Program (VCP) under EPCRS
to correct a failure to timely adopt a written 403(b) plan document.
is made up of three distinct correction programs: the Self-Correction Program (SCP), the Voluntary Correction Program with Service Approval (VCP) and the Correction on Audit Program (Audit CAP).
Operational errors that relate to failure to comply with the terms of a plan that are correctly drafted originally may be eligible for self-correction under EPCRS
Under the prior iteration of EPCRS
, Revenue Procedure 2008-50, correctable qualified plan failures included document, operational, demographic and employer eligibility failures.
It also ensures that EPCRS
is consistently administered.
As to specific corrections, none are spelled out by the EPCRS
, therefore, its rules concerning excess allocations apply, Watson says.
Her practice includes representing clients before the IRS and US Department of Labor in obtaining prohibited transaction exemptions, private letter rulings and relief under correction programs such as EPCRS
98-22 and the administration of EPCRS
and specifically requests (1) comments regarding the extent to which a fixed (as opposed to an indefinite) self-correction period encourages prompt, voluntary correction and (2) suggestions for items that should be included in forthcoming guidance on permissible correction methods.
Specifically, ASPPA and CIKR recommend that the service modify the safe harbor correction methods under EPCRS
to provide that, in the case of a plan with automatic enrollment, if an employee is inadvertently excluded from the plan or his deferral rate is not automatically increased in accordance with the plan's provisions, there would be an acceptable correction method.