Waiver of interest and/or penalties for an amended return due to a fai

[Guest whistler]

Has anyone come across this? I have a non-calendar plan year that failed the ADP test. The employer elected to have corrective distributions for excess contributions completed within the 2 1/2 months. The affected HCE's will have to amend their tax returns now. Because they have to amend their returns, they will get penalized with interest. Is there any relief that waives interest and/or penalties to the HCE? It seems the IRS should allow for some kind of waiver because the HCE would have no way of knowing the final results until after the plan year end. If anyone has come across this, I would greatly appreciate any guidance. Thank you!