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IRS Makes Changes to EPCRS

The IRS recently published two revenue procedures, which make various modifications and clarifications to the Employee Plans Compliance Resolution System (“EPCRS“), as set forth in Rev. Proc. 2013-12. Of particular note under Rev. Proc. 2015-27 (released on March 27) is a clarification that, with respect to certain plan overpayments, a plan sponsor is not necessarily required to attempt to recoup overpayments directly from participants and beneficiaries. Rev. Proc. 2015-27 also reduced the Voluntary Correction Program fees required for certain participant loan failures. The second revenue procedure, Rev. Proc. 2015-28 (released on April 2), provides new safe harbor correction methods for employee elective deferral failures under 401(k) and 403(b) plans (including plans that have automatic contribution features). Pursuant to these safe harbors, the qualified nonelective contributions that were previously required under EPCRS to correct elective deferral failures may be reduced or eliminated if the failures are corrected within a specified period of time and other conditions are met.

A copy of Rev. Proc. 2015-27 is available here, and Rev. Proc. 2015-28 is available here.

The lawyers of our Employee Benefits and Executive Compensation Practice Group are readily able to assist companies on a nationwide basis with implementing sophisticated benefit plans and providing answers to their most challenging compensation issues. Additionally, our lawyers are well aware of the daily employee benefits challenges facing companies of all sizes and are capable of helping in-house lawyers and human resources personnel with the day-to-day advice and guidance necessary to properly administer employee benefits plans.

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