Self Correct if submitted under VCP?

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....

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.

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.

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.