Are EPCRS corrections available to non-electing church plans?

[Trekker]

A non-electing church plan erroneously excluded eligible employees and did not allow them to make elective deferrals or receive the match. The correction methods are clear when you have a qualified plan. Would the same corrective measures apply to a church plan and will the IRS accept a VCP application for a church plan?

Thanks for any insights.

[John Feldt ERPA CPC QPA]

Generally, Yes. You can file VCP for a church plan. Certain corrections may require having or obtaining a determination letter. See section 4.10 of Revenue Procedure 2013-12. Since this is a nonelecting church plan, you have no reliance on any opinion/advisory letter if the plan used a prototype or vol sub document.