Eligible for SCP or no, alternatives?

[John A]

A plan sponsor establishes a new plan as of the 2000 plan year by adopting a new prototype document. The prototype document is submitted for a GUST determination letter in 2001 but has not yet received a response. For the 2000 plan year, ineligible employees are given a profit sharing contribution.

Is this situation eligible for correction under the IRS Self-Correction Program (SCP) due to the prototype having applied for a determination letter, or is it ineligible for SCP? If it is ineligible for SCP, what actions should the plan sponsor take to correct the contributions for the ineligible employees?