Loan Corrections

If a participant terminated let's say in July 2021 and made no further payments on the loan, but the loan was not reported on a 2021 1099-R, can the EMployer report under a 2022 1099-R under EPCRS?  I think yes.  The program indicates that this is an option in the event of a "deemed distribution under 72(p)."  Even though this is a loan offset when I look at 72(p) it seems sufficiently broad to conclude that what I describe is a deemed distribution under 72(p).  The terminology of course gives me pause so I'm not 100% confident in my  answer...  EPCRS Section 6.07 is the site.

Actually the term "loan offset" is defined in "1.72(p)-1 - Loans treated as distributions" so I am feeling much much more confident in the availibility of this correction option.