Self Correct if submitted under VCP?

[tsrl01]

We submitted our plan to the IRS under VCP about 6 months ago and just found an issue completely unrelated to the VCP submission.  I do not see any requirements that we can't still self correct the recently identified problem, but wanted to see if anybody had a different opinion.  In my mind, since there isn't a specific exclusion, as long as the issue would otherwise qualify for self correction, I can.  Any insight would be appreciate - because maybe I completely missed an all cap requirement that says differently....

 

[Nate S]

If found concurrently under audit, then unrelated issues would be treated at the same time under CAP.  VCP and SCP are almost always handled independently, although a series of failures can become a single issue dependent upon circumstances and significance.  You can also seek a PLR if the significance is in question and you cannot draw a clear distinction under SCP.

[rocknrolls2]

According to the most recent EPCRS Rev Proc, even if the plan is under Audit CAP, it is possible to self-correct. In many cases, the agent handling the Audit CAP will specifically allow you to use SCP for the self-correctable items. I see no reason why you could not self-correct merely because you submitted a VCP application. I assume that you have not yet heard from the agent assigned to review the VCP application. In that case, go full speed ahead.

[Luke Bailey]

On 10/12/2022 at 1:17 PM, tsrl01 said:

We submitted our plan to the IRS under VCP about 6 months ago and just found an issue completely unrelated to the VCP submission.  I do not see any requirements that we can't still self correct the recently identified problem, but wanted to see if anybody had a different opinion.  In my mind, since there isn't a specific exclusion, as long as the issue would otherwise qualify for self correction, I can.  Any insight would be appreciate - because maybe I completely missed an all cap requirement that says differently....

 

I don't think you missed anything, tsrl01.