Incorrect ADP refund

[Guest niceguymike1]

ADP tested what we later learned was incorrect comp and incomplete census data, failed test, and refunds were done. After obtaining full and correct data, the test passed. What do we do about the ADP refund made unnecessarily?

[Guest ppapdx]

It's an operational failure. The IRS refers to it as an "overpayment". The plan sponsor should use the Self Correction Program or Voluntary Correction Program to correct the failure. Check out the EPCRS (Revenue Procedure 2013-12), section 6.06(3) for a safe harbor approach for correcting. It generally involves the plan sponsor making a reasonable attempt to have the funds returned to the plan.

[Guest niceguymike1]

It's an operational failure. The IRS refers to it as an "overpayment". The plan sponsor should use the Self Correction Program or Voluntary Correction Program to correct the failure. Check out the EPCRS (Revenue Procedure 2013-12), section 6.06(3) for a safe harbor approach for correcting. It generally involves the plan sponsor making a reasonable attempt to have the funds returned to the plan.

Yeah, I thought that's where we were heading; thanks for reply!