October 9, 2018

Mandatory E-file of Retirement Plan Corrections (article)

Qualified retirement plan errors can be corrected under certain conditions, as delineated in the IRS’ Employee Plans Compliance Resolution System (EPCRS).  The EPCRS is divided into three parts: the Self-Correction Program, the Voluntary Correction Program, and the Audit Closing Agreement Program.

The IRS released a Revenue Procedure on September 28, 2018 (Rev. Proc. 2018-52) making a few modifications to the Voluntary Correction Program (VCP).  The primary change made by this IRS pronouncement is that all corrections made under the VCP must be done electronically through Pay.gov.  This change is mandatory beginning April 1, 2019.  Between January 1, 2019 and March 31, 2019, a submission can be made electronically, or by paper.

Any plan sponsor contemplating utilizing the voluntary correction program should become familiar with these updated procedures.  Additional guidance is also available on the IRS’ dedicated webpage, Updated Retirement Plan Correction Procedures.


The information contained in this article is provided as general guidance and may be affected by changes in law or regulation. This article is not intended to replace or substitute for accounting or other professional advice. Please consult a CBIZ professional. This information is provided as-is with no warranties of any kind. CBIZ shall not be liable for any damages whatsoever in connection with its use and assumes no obligation to inform the reader of any changes in laws or other factors that could affect the information contained herein. 

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