failure to implement auto escalation

I received and e-mail in late January that a client wanted to add auto escalation to their plan in time for the first paycheck in February. They were persuaded to make it effective March 1 to allow the recordkeeper time to distribute a notice. The client insisted that the increases were to coincide with each employee's hire date anniversary. The amendment to make these changes was signed in February, but the SMM has not yet been distributed.

Yesterday I learned that the notice was mailed with the March 31 statements, no increases have been implemented yet, and the client only wants the increases to be effective on the first of the quarter following the employment anniversary. Because the notices were mailed late, the client doesn't believe that any correction is necessary.

What is the correction for failure to provide a timely notice of an automatic escalation provision? Based on the notice going out in early April with an effective date of March 1, what is the soonest that they should implement an increase?