IRS Updates Retirement Plan Correction Procedures

On September 28, 2018, the IRS released Revenue Procedure 2018-52. The Revenue Procedure makes changes to the IRS Employee Plans Compliance Resolution System (“EPCRS”), which is the IRS’ comprehensive correction program for qualified retirement plans.  The primary purpose of the Revenue Procedure is establishing the process for filing correction applications and paying the applicable user fee through the www.pay.gov website.

Beginning April 1, 2019, the IRS will no longer accept paper applications meaning that plan sponsors are required to use pay.gov to submit their application and pay their user fees.  During a transition period running from January 1 – March 31, 2019, plan sponsors may, but are not required to, file their EPCRS applications online.

In order to file, applicants are required to create an account and complete and sign a Form 8950. The 8950 and the related submission documents will be uploaded as a single pdf. After payment is made through the site, a receipt and Tracking ID will generate and that Tracking ID will serve as the IRS control number for the EPCRS submission.  Applications that exceed the attachment file size limit are required to be faxed to the IRS. To supplement or modify a previously submitted application, applicants are required to call the VCP status inquiry line and the IRS will assist in determining how the supplement should be filed.

More on the new EPCRS electronic submission process can be found here.