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Guest Article

IRS Expands Correction Program for 2001

The Internal Revenue Service (IRS) has revised and expanded the Employee Plans Compliance Resolution System (EPCRS). Released Jan. 19, Revenue Procedure 2001-17 modifies those procedures for EPCRS set out in Rev. Proc. 2000-16 released last year. The updated EPCRS system is effective May 1, 2001, but plan administrators may implement the new procedures now.

The significant modifications made by the new Revenue Procedure include:

Anonymous Submission Procedure. The submission procedure now allows plan sponsors, excepting simplified employee pension or voluntary compliance group ("VCGroup") plans, to submit a request on an anonymous basis.
"Housekeeping" Changes. Rev. Proc. 2001-17 combines the previous programs that allow voluntary correction with IRS approval - VCR, standardized VCR program (SVP), Walk-In CAP, and the TVC (for 403(b) plans) - into a single voluntary correction program, called VCP. In addition, the previous APRSC program is renamed the Self-Correction Program (SCP).
Changes to Reflect Different Types of Submitters. The new revenue procedure broadens the submission procedures under the VCP to allow certain organizations, such as master and prototype sponsors or third-party administrators, to receive a compliance statement for correcting failures that affect more than one plan sponsor (VCGroup). Rev. Proc. 2001-17 also expands EPCRS to add new procedures specially designed for small employers that sponsor simplified employee pensions.
Merger and Acquisition Relief. Rev. Proc. 2001-17 extends the duration of the self-correction period under the SCP (the former APRSC) for significant operational compliance failures where the plan sponsor accepts a transfer of plan assets or effects a plan merger in connection with a corporate merger, acquisition or other transaction.
Ineligible 401(k) Sponsors. Correction for employers that were not eligible to sponsor 401(k) plans at the time they adopted their plans is permitted under the new revenue procedure.
Errors Discovered on IRS Audit. The new revenue procedure emphasizes that the ability to self-correct insignificant failures continues to be available under the SCP during a plan examination, whether the failure is identified by the plan sponsor or by the IRS.

However, Rev. Proc. 2001-17 also clarifies that a failure not disclosed by the plan sponsor or discovered by the IRS during the processing of a determination letter submission is subject to the sanction structure of Audit CAP.

The Service expects to update EPCRS on a periodic basis, and encourages comments on how to improve the program. Any comments should be sent to: Internal Revenue Service, Attention: T:EP:RA:VC, 1111 Constitution Avenue NW, Washington, D.C. 20224.

Reprinted with permission from the March 2001 supplement to The Pension Plan Fix-It Handbook, ©Thompson Publishing Group, Inc., 2000. All rights reserved.

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