Guest TaxedToDeath Posted April 15, 2014 Share Posted April 15, 2014 A plan failed its 2012 ADP test but the refunds were processed in 2014. Can EPCRS be used? Link to comment Share on other sites More sharing options...
BG5150 Posted April 16, 2014 Share Posted April 16, 2014 Yes. If you already did the refunds, than a 1-to-1 QNEC should probably be done. Problem might be that you cannot disaggregate the otherwise excludables. So, if you have to re-run the test with everyone in it, you may get higher refunds. SCP, not VCP, though. QKA, QPA, CPC, ERPATwo wrongs don't make a right, but three rights make a left. Link to comment Share on other sites More sharing options...
Guest skim401k Posted November 14, 2014 Share Posted November 14, 2014 After all my research, I couldn't identify where it says that employers using the prior year method have a different way of correcting untimely ADP corrections (past the 1 year correction period) than employer using the current method. Do you think only 1-to-1 QNEC with refunds option is available for plans that use the Prior Year method? And that the QNEC option is only available to current year plans and that prior year plans must use the One-to-One Method to correct? Link to comment Share on other sites More sharing options...
Tom Poje Posted November 17, 2014 Share Posted November 17, 2014 my copy of Rev Proc 2013-12 (EPCRS) under Appendix B One-to0one correction method (1)(b)(iv)(B)(2) [page 91] says (2) This paragraph (1)(b)(iv)(B)(2) applies to a plan that uses the prior year testing method described in §§ 1.401(k)-2(a)(2) and 1.401(m)-2(a)(2) and, for periods prior to the effective date of those regulations, Notice 98-1. Paragraph (1)(b)(iv)(B)(1) is applied by substituting "the year prior to the year of the failure" for "the year of the failure." so unless something has changed in the last year I know nothing about it appears you can use this for prior years. Link to comment Share on other sites More sharing options...
Guest Rebel TPA Posted November 19, 2014 Share Posted November 19, 2014 What about a situation where a new plan using prior year testing and the "deemed 3%" rule fails ADP testing and didn't make the refunds within the 12 month deadline? I didn't see anything in EPCRS addressing that scenario. It doesn't seem logical to me that I should make the QNEC to NHCEs from the prior year when the plan didn't exist in the prior year. The EPCRS correction method doesn't allow disaggregation of otherwise excludable employees. Are we required to use the EPCRS test results as our prior year percentages for the following year or is the restriction solely for the calculation of the refund and QNEC? Link to comment Share on other sites More sharing options...
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