After March 31, 2019, all Voluntary Correction Program submissions must be made electronically using Pay.gov

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IRS Retirement Plan Correction Program

The IRS maintains a correction program that permits any size business or organization that sponsors a retirement plan (including SEP and SIMPLE IRA plans) to identify and correct problems they find. This correction program, the Employee Plans Compliance Resolution System (EPCRS), is outlined in Revenue Procedure 2018-52.

Under the Self-Correction Program (SCP), you can correct many plan mistakes without contacting the IRS.

• Identify and correct mistakes using the procedures in EPCRS
• Do not notify the IRS
• Pay no fees to the IRS
• Your plan’s tax benefits are preserved

The Voluntary Correction Program (VCP) works for mistakes that are not eligible for self-correction or if you want IRS assurance about how you corrected a mistake.

• You must make a written submission and pay a compliance fee to the IRS, prior to an IRS audit
• Disclose the self-identified problems along with a proposal to fix them
• The IRS determines if the proposal is acceptable and issues a compliance statement documenting approval
• Your plan’s tax benefits are preserved

If you want to learn how to find and correct mistakes in a
small business retirement plan, visit Correcting Plan Errors. Information on that webpage, including the Fix-it-Guides, can help you learn how to use the IRS correction program to correct mistakes in your retirement plan.  

VCP Submissions on Pay.gov

Beginning April 1, 2019, you must make all VCP submissions electronically through Pay.gov. Any paper VCP submissions sent to the IRS with a postmark after March 31, 2019, will be returned to the applicant.

Note the following tips when making a VCP submission electronically through Pay.gov:

• A VCP application is not considered filed with the IRS until the VCP user fee has been paid and the Pay.gov website generates a payment confirmation receipt. If you don’t have a receipt with a Pay.gov Tracking ID #, you haven’t made a VCP submission to the IRS.
• Please include all required VCP submission items in your PDF file that’s uploaded to the IRS. See Rev. Proc. 2018-52, section 11.04 and, if applicable, enclosure lists associated with the model VCP submission forms in the Form 14568-A through Form 14568-I series.
• The completed Form 8950 is uploaded automatically, so don’t include any copy of the Form 8950 as part of the uploaded PDF file containing the VCP submission documents.
• Place the VCP submission documents in the uploaded PDF in the order specified by Rev. Proc. 2018-52, section 11.11.

Prior to making a submission, please review the electronic VCP submission process outlined in Revenue Procedure 2018-52. For more information, check out this IRS video and review Updated Retirement Plan Correction Procedures that discuss the VCP submission process.