Correcting a failed ACP Test from prior Plan Year

[msmith]

Plan failed the ACP Test for the 2015 Plan Year and corrective distributions were made before 03/15/2016. The Plan also failed the ACP Test for the 2016 Plan Year and corrective distributions were made before 03/15/2017. For both Plan Years, the Prior Year Testing Method was used.

While reconciling the Match contribution for 2016, it was discovered that 1 Match deposit was actually for the 2015 Plan Year. I have re-run the 2015 ACP Test and 1 HCE needs more distributed and the other HCE had too much distributed. The revised 2015 test also changed my NHCE Prior Year percentage - used for the 2016 Test.

The final corrective results, over the 2 Plan Years, show that 1 HCE's net result is that he had too much distributed. The other HCE did not require a correction for 2016 - but did not have enough corrected for the 2015 revised Test.

Is EPCRS the only remedy available? The total "net" correction still due is less than $25.00. 

[Mike Preston]

I don't see why you can't use SCP.  Do something reasonable.  Document it.  Follow the SCP procedures.  Sleep well at night.  THe absolute worst that can happen is the plan is audited and the IRS nitpicks the self-correction and requires something different.  There is no way, based on what you have described, that the IRS will push for Audit CAP.

[CuseFan]

even IRS would have to admit the differences are immaterial

[msmith]

Agreed. Thanks to all that replied.