403(b) Plan correction - failure to make mandatory distribution/rollover

[holdco]

Hello everyone

A quick question. Employer sponsors a 403(b) plan that failed to cash out participants with vested balances less than $1,000, and failed to roll over participants with balances between $1,000 and $5,000 when they didn't make an election otherwise. Does this require a VCP application? It doesn't look like this is the kind of operational failure that is correctable yet under EPCRS.

What if the same failure happened in a defined contribution plan? That has to be VCPed, correct?

Thanks so much!