Incorrect ADP Refund to an HCE

A plan failed the ADP test for the 2020 plan year and a refund was properly issued to the HCE by 12/31/2021.  When preparing the 2021 testing, the client discovered some of the compensation reported for 2020 was incorrect.  The 2020 ADP test was re-run with the correct compensation and the HCE is now due an additional $184.00.  Since we are past the 12 month correction period, will the refund fall under EPCRS and a one-to-one correction required?

I would think that's an appropriate way to self-correct an insignificant error.  Obviously document the calculations for any audit.

Are you sure you are past the correction period?  The new EPCRS extended the timeline.....

I think there's confusion here between the statutory correction period of one year to avoid the excise tax (that has expired) and the 2-year (now 3-year) SCP correction period, which actually would not apply here anyway since it is certainly an insiginificant amount. But you are under EPCRS because went past the 1 year.