457(b) Plans missed deferrals

Hi -- I have a client that has failed to implement participant deferrals into a state 457(b) plan that the employer participates in. My understanding is that, since there is limited opportunity to submit corrections to the IRS under Section 4.09 of EPCRS, and Reg 1.457-9 provides that governmental entities have until the first day of the plan year that begins more than 180 days after the IRS notifies them of the failure to correct their plan failures, practitioners interpret that to mean that corrections for 457(b) plans can generally follow those prescribed under EPCRS for qualified plans. So in this case we would corrective contributions for the participant's missed opportunity to make a contribution/invest (e.g., 50% of missed deferral) as under EPCRS. 

Is that understanding correct?

Thanks!

I have the exact same question and noticed you had not gotten a response yet however mine is in the Tax-Exempt 457(b) space.