Revenue Procedure 2021-30 adds two new benefit overpayment correction methods that encourage employers to avoid seeking recoupment of benefit overpayments made to participants and beneficiaries, either by not requiring correction if the plan satisfies a specified funding level, or by limiting the amount to be recouped under certain circumstances. In addition, the revenue procedure eliminates the VCP anonymous submission procedure and adds an anonymous, no-fee, VCP pre-submission conference procedure. The revenue procedure also expands correction by plan amendment under SCP, extends the end of the SCP correction period for significant failures by one year, and extends the sunset of the safe harbor correction method for certain missed elective deferrals by three years.
Revenue Procedure 2021-30 will be in: 2021-31, dated 08/02/2021.