ADP Test Refunds

[PensionPro]

A calendar year 401(k) plan failed the ADP tests and refunds were made to the HCEs by 03/15. After 03/15 it was determined the census information was misreported, and the plan actually passes the ADP test based on the new accurate information.

Can we reverse the refund transactions and have the HCEs send back their refunds? What is the recommended course of action in this situation? Thanks very much!

[QDROphile]

EPCRS, Rev. Proc. 2008-50.