The New (Self-Correction) Landscape of EPCRS: Alternatives to VCP?

Benefits and executive compensation partner Heather Abrigo and associate Betsy Olson coauthored the article “The New (Self-Correction) Landscape of EPCRS: Alternatives to VCP?” for the Journal of Pension Benefits.

In their article, Abrigo and Olson highlight that at the end of February 2020, the IRS indicated a shift in process for review of VCP submissions that could result in more submissions being referred to audit. This position is at odds with the purpose of EPCRS (to encourage proactive correction). Abrigo and Olson’s article is a discussion of the changes in the IRS’s policies as they relate to EPCRS, the SCP options in EPCRS (including certain important limitations on the use of those options), and provides examples of VCP corrections that are not permitted.