The IRS doesn’t want plan sponsors to pay too much. And yes, you read that right.
The IRS recently published guidance (Avoid Overpaying User Fees for Your Voluntary Correction Program Submission) reminding plan sponsors of the steps they can take to avoid overpaying correction fees. This guidance was issued in response to an increase in overpayment of user fees with some retirement plan correction applications.
The Employee Plans Compliance Resolution System (EPCRS) was reissued last year with the publication of Revenue Procedure 2016-51. This new procedure removed the user fee schedule from EPCRS, and user fees are now provided as part of an annually published list. For 2017, Appendix A of Revenue Procedure 2017-4 provides the listing of fees.
The IRS is also reminding plan sponsors to include the September 2016 version of Form 8951 (User Fee for Application for Voluntary Correction Program) with applications because older versions contain inaccurate information.