Starting April Fools’ Day, all Voluntary Correction Program (VCP) submissions and fee payments under the IRS’s Employee Plans Compliance Resolution System (EPCRS) must be made online; the IRS will no longer process paper VCP submissions. The IRS announced this change on September 28, 2018, in Revenue Procedure 2018-52, which modifies the EPCRS by replacing Revenue Procedure 2016-51 as of January 1, 2019.  

The EPCRS allows plan sponsors to correct retirement plan qualification failures and has three primary programs: VCP, the Self Correction Program and the Audit Closing Agreement Program (a.k.a. Audit CAP). 

As announced in the new Revenue Procedure, plan sponsors will be required to make VCP submissions and pay applicable fees online starting April 1, 2019. During a January 1, 2019 to March 31, 2019 transition period, plan sponsors may either make VCP submissions online, or continue making paper VCP submissions. The Revenue Procedure allows plan sponsors to authorize their legal representatives to sign and submit their VCP submissions online. When they make online submissions on behalf of their clients, authorized representatives must include a penalty of perjury statement and an IRS power of attorney form.

In addition to the VCP changes outlined above, the new Revenue Procedure includes many other clarifications. Among these are changes allowing for online payment of fees and sanctions. And the potential for future enhancements to EPCRS is highlighted. The Revenue Procedure also includes an invitation to the public to provide comments on how to improve the EPCRS. No deadline was announced for submitting such comments.

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