January 14, 2013
Authored by: Chris Rylands
After a long wait, an updated Revenue Procedure for the Employee Plans Compliance Resolution System (EPCRS) was released in the form of Rev. Proc. 2013-12. The new Revenue Procedure makes some important changes to the EPCRS.
As many plan sponsors know, the EPCRS includes the self-correction program (SCP), which requires prescribed corrections but does not require submission to the IRS; the voluntary correction program (VCP), which requires both prescribed corrections and submission to and approval by the IRS; and correction of problems discovered on audit (Audit CAP).
The purpose of the updated Revenue Procedure is to improve some features of the EPCRS and clarify others, based in large part on comments from the employee benefits community. The IRS expects to make more changes of this type in the future, also based on comments from the employee benefits community. Generally speaking, the IRS was responsive to