Correction for missed ER match

[Guest KLM3]

During a recent audit, it was discovered that the ER failed to make a match for some participants over the past two years, totaling approximately $900 in each year. What is the SCP for this? Do tests have to be re-run? Do the 5500s have to be amended? Thanks for your help.

[ETA Consulting LLC]

This is entirely contingent upon the particular facts and circumstances of the case where you would take all "reasonable" steps necessary to place the individuals in the same position they would've been in had their contributions not have been missed. If the individuals were NHCEs, then you know the additional contributions wouldn't have adversely impacted the test, so there would be no need to re-run the test. Everything remains contingent upon the particular facts of your case. I wouldn't revise the 5500's. The only revision, if done, would be to log those amounts as a receivable at year end; and the 5500 may already be completed on a cash basis. Remember, contingencies is the key here

Good Luck!