Correction for not timely starting required minimum distributions on an active employee

[gle318612]

We missed starting an active employee/participant's required minimum distributions in 2008. We plan on using VCP (so that the Service will waive the excise tax on participant) to correct under EPCRS. However, from the participant/taxpayer side....does the participant need to complete and submit the IRS form 5329 (the instructions to which are confusing) by the tax filing date for his 2008 return? That seems duplicative of the plan's correction but...???

Any other help/guidance on correction is appreciated. Luckily, we haven't had a failure to start rmds for many, many years.

Thanks.