Employee gone before excess contribution paid out

[panther]

Plan allowed excess contributions and failed the ADP test for 2002. It needs to distribute excess contributions but 2 HCEs due distributions are no longer employed and already rolled their funds over to an IRA. Is there anything the employer can do to correct the defect as to these 2 former employees?

[QDROphile]

Review the EPCRS procedures. At a minimum, the plan needs to advise the former participants of the excess and the consequences of rolling over amounts that are ineligible for rollover.