We pulled the file, mapped every failure, and built the submission around one workhorse document, Form 14568-D. That is the schedule the IRS expects you to use to standardize disclosure and correction for SIMPLE IRA issues inside a Voluntary Correction Program submission.
Key Takeaways
- Form 14568-D, Schedule 4 is the IRS model schedule for SIMPLE IRA failures within a VCP submission, and you must use the current version without changing its format or language.
- Your single VCP package runs through Pay.gov with Form 8950 and the user fee process on Form 8951. Keep your combined attachment under 15 MB, or fax overflow with the Pay.gov Tracking ID.
- Use 14568-D to disclose facts, identify affected participants, and document your correction method and earnings calculations for missed deferrals, employer contribution errors, excess amounts, or late deposits.
- Follow Rev. Proc. 2021-30 for ordering, required narratives, and single-PDF rules. The Pay.gov Tracking ID becomes your IRS control number for the file.
- If someone will represent the sponsor, include Form 2848. If you only want copied correspondence, use Form 8821.
What Form 14568-D does, and why it matters
Form 14568-D is the IRS model VCP schedule for SIMPLE IRAs. It gives you a fixed structure to describe the failures, document the math behind corrections and earnings, and state the procedural fixes you are putting in place so the problem does not recur. The IRS allows you to pair this schedule with the core Model VCP Compliance Statement, Form 14568, or use the schedule on its own inside your VCP package, but either way you must use the current, unmodified version.
Behind the scenes, EPCRS in Rev. Proc. 2021-30 sets the playbook for VCP submissions. It requires a single combined PDF of your attachments, uploaded through Pay.gov with Form 8950, and it outlines the evidence the IRS expects to see, from narratives to worksheets to signatures. If your bundle is larger than 15 MB, the IRS instructs you to fax the overflow to the dedicated number and reference the Pay.gov Tracking ID on your cover sheet.
Put simply, 14568-D is how you talk to the IRS about a SIMPLE IRA failure in a way that is complete, consistent, and easy to review.
When to use Schedule 4 for SIMPLE IRAs
Use Form 14568-D when your VCP submission involves a SIMPLE IRA and you need to correct operational or document failures. The schedule covers common SIMPLE mistakes, including employer eligibility failures, missed or misapplied nonelective or matching contributions, failure to give employees the chance to defer, excess amounts, and document updates. The IRS’s own SIMPLE IRA Fix‑It Guides steer sponsors to 14568-D for these scenarios.
A few practical notes:
- Even if you are not using the core Form 14568, you can still use Schedule 4 to standardize your facts and fix. The IRS encourages it.
- Consider whether SCP applies first, but if a failure is significant or outside SCP limits, VCP with 14568-D is the safer path to formal IRS sign‑off.
- For sponsor ineligibility, the Schedule requires you to cease new contributions as of a date no later than your VCP filing date. Plan years must be listed clearly.
Build a complete VCP submission, step by step
The core forms
Your submission starts on Pay.gov with Form 8950. You attach a single PDF that contains your narratives, the signed penalty-of-perjury statement when applicable, Form 14568-D and any schedules you use, plan and payroll evidence, and other exhibits. You pay the Form 8951 user fee inside Pay.gov, and the site emails you a confirmation showing the Tracking ID the IRS uses as your control number. Keep that email and PDF receipt with the working file.
The 15 MB rule, and what to do if you exceed it
As of January 2025, the file you attach to Form 8950 cannot exceed 15 MB. If you have more documentation, fax the overflow to the IRS at 855‑203‑6996 and include the EIN, Applicant Name, Plan Name, and Pay.gov Tracking ID on the cover sheet. The IRS calls out this step in the Form 8950 instructions.
Narrative and ordering
Rev. Proc. 2021-30 tells you to combine all required items into a single PDF and follow the suggested ordering in section 11. That means facts first, then failures, then method of correction, participant impact, calculations, and changes to procedures. Treat 14568-D as the standard framework, and map your narrative to it so every number in your worksheets ties to a line on the schedule.
The data 14568-D captures, and how to present it
Think of Schedule 4 as your cover grid for the entire correction. You start with the plan name, EIN, and a three‑digit plan number. For SIMPLE IRAs, the IRS guidance often uses “990” when a plan number does not exist, and it expects the identifiers on 14568-D to match what you enter on Form 8950. Consistency across forms makes intake easier and reduces back‑and‑forth with the reviewer.
Next, describe the failures and list the plan years, the population affected, and the correction you will make. When you correct missed employer contributions or missed deferral opportunities, the schedule points you to standard methods, including a 3 percent assumed deferral when employees were denied the chance to contribute and a 50 percent missed‑deferral make‑up contribution for that specific failure, all adjusted for earnings through the deposit date. These are built into the schedule’s text.
Be precise about participants. In your attachments, include each affected person’s name, identifying details, compensation period, what should have happened, what did happen, and the difference. Then tie your math to payroll, custodian confirms, and worksheet totals. The IRS Fix‑It pages also remind sponsors to attach the signed SIMPLE plan document that applied during the failure years, for example Form 5304‑SIMPLE or 5305‑SIMPLE, if you used the IRS model.
The reviewer should be able to re‑create your totals from your worksheets without opening your payroll system. If they can do that, your submission moves faster.
Describing failures clearly without extra words
Use plain, dated statements. Cite the plan clause that applied, the date the failure began, and the date you discovered it. For employer eligibility failures, check the box and list the years when the 100‑employee rule or “other plan” rule was violated. For missed employer contributions, check the correct formula box, such as 2 percent nonelective or match up to 3 percent, and show the plan years that formula applied. The schedule is designed to hold those details and your totals.
Include a short chronology in your narrative attachment. Explain how you discovered the issue, the steps you took to verify it, and the dates you completed each corrective deposit. The IRS’s kits and Fix‑It Guides are unambiguous about using 14568‑D and following Section 11 of the revenue procedure when you build your package.
A simple summary table you can reuse
| Metric | Amount or Count | Notes |
| Affected participants | [number] | Cross‑foot to worksheets |
| Employer contributions missed | [$/years] | Show by year and formula |
| Missed deferral make‑up base | [$/years] | Use 3 percent assumption where applicable |
| Earnings added | [$/years] | Method noted below |
| Total corrective deposits | [$/years] | Ties to custodian confirmations |
Document your earnings method. The current 14568‑D lets you use actual SIMPLE IRA investment results, the Department of Labor’s VFCP online calculator rate when actual returns cannot be determined, or a combination of actual and VFCP for missing periods. Pick one approach, apply it consistently, and say which years it covers.
Correction methods that the IRS expects to see on 14568‑D
Missed deferral opportunity
When eligible employees were not offered the chance to defer, 14568‑D directs you to fund a make‑up equal to 50 percent of the estimated missed deferral, with the estimate based on an assumed defer rate of 3 percent of compensation, plus earnings through the correction date. This is a standardized method on the form, so write your worksheets to mirror that language and calculation.
Employer match or nonelective shortfalls
For missed employer contributions, compute what should have been contributed under the plan formula, subtract what was actually deposited, and fund the shortfall with earnings from the last day of the plan year to the correction date. If you denied deferrals and the plan provided a match, the form assumes the employee would have deferred 3 percent, which drives the corrective match. Again, tie it to the form’s lines and add your year‑by‑year totals.
Excess amounts and late deposits
If you contributed excess amounts, 14568‑D includes checkboxes and language for distributing excess deferrals with earnings, returning excess employer contributions with appropriate reporting, and applying the small $250 or less excess rule where allowed under EPCRS. For late deposits, calculate and deposit lost earnings using your chosen method and show the proof of posting from the custodian.
Tip, especially during peak season: batch confirmations from your custodian by plan year, then attach the batch to your worksheet packet so the IRS can verify totals quickly.
Filing logistics with Forms 8950 and 8951 on Pay.gov
Your VCP journey starts on Pay.gov. You will upload a single non‑fillable PDF that contains your entire submission package in the order the IRS expects, then you will pay the user fee tied to Form 8951. Keep your process clean so intake is smooth and you avoid preventable delays.
Step by step, from desktop to Pay.gov
- Prepare the forms
- Complete Form 8950 and your Form 14568-D (Schedule 4).
- If you are using the base Form 14568 Model Compliance Statement, finish it and any other schedules.
- If someone will act on the sponsor’s behalf, include a signed Form 2848. If you only want copied correspondence, include a signed Form 8821.
- Assemble one non‑fillable PDF
- Print each completed form to PDF so the file is non‑fillable.
- Merge your documents in this order: cover letter, narratives, Form 14568-D and any schedules, Form 14568 if used, plan documents or amendments, payroll and custodian evidence, signed statements, Form 8950, and fee exhibit.
- Aim for clear file names, for example 01_Cover, 02_Narrative, 03_14568D, 04_Worksheets, 05_Evidence, 06_8950.
- Upload and pay on Pay.gov
- Create or sign in to your Pay.gov account.
- Start the Form 8950 submission, attach your single PDF, and pay the fee by ACH, debit, or credit.
- Save your Tracking ID confirmation as a PDF. Keep it with your working papers.
- Handle size and overflow the right way
- Keep the combined PDF at or under 15 MB.
- If you must send overflow, fax the remainder and include the EIN, plan name, applicant name, and Pay.gov Tracking ID on the cover.
- Log what went by upload and what went by fax. Keep all send receipts.
Tip for peak season, use a simple index page at the front of your PDF, then bookmark each section. It cuts IRS review time and lowers the odds of a follow‑up letter asking for basics you already included.
Representation and correspondence, 2848 vs 8821
You decide who can speak for the plan sponsor and who simply receives copies. That choice determines whether you file Form 2848, Form 8821, or both.
| Scenario | Use this form | What it allows |
| You want a representative to discuss terms, sign agreements, and receive mail | Form 2848 | Full representation and confidential info access |
| You only want a third party to get copies of letters and emails | Form 8821 | Information access, no authority |
| You want a rep to act, and a separate team to get copies | Both | 2848 controls representation, 8821 handles copies |
Practical details that save time
- List the tax matter as “VCP, employee retirement plan,” include the EIN and plan years.
- Make sure authorized signers sign and date each form.
- If you submit both forms, remember that 2848 authority governs any overlap.
Sample timelines and implementation milestones
Most firms move from scoping to filing in 60 to 90 days. That window gives you time to inventory failures, draft narratives, create worksheets, get signatures, and collect source evidence from payroll and the custodian.
Pre‑submission preparation, a realistic plan
- Weeks 1 to 2, discovery and scoping Map failures by type and year, identify affected participants, pull the plan document and any amendments for those years, and export payroll data by pay period.
- Weeks 3 to 5, calculations and drafts Build worksheets, choose your earnings method, and draft the schedule narratives. If employer eligibility is an issue, set the cease date for new SIMPLE contributions and prepare the amendment path.
- Weeks 6 to 7, assembly and signatures Complete Form 14568-D, finish the narrative package, print everything to non‑fillable PDF, and obtain sponsor signatures. Prepare Form 8950 and confirm the user fee.
- Week 8, Pay.gov filing Upload the single PDF, pay the fee, and archive the Tracking ID. If you have overflow, fax it the same day and keep the transmission report.
- Weeks 9 to 12, intake and follow‑ups Track for IRS acknowledgment. Respond quickly if the reviewer asks for clarifications. Keep your project file current so answers are at hand.
A simple milestone table you can copy
| Milestone | Target date | Evidence kept |
| Discovery complete | [Date] | Issue log, failure map |
| Worksheets finished | [Date] | Excel or PDF workpapers |
| Sponsor signatures | [Date] | Signed statements, 14568-D |
| Pay.gov submission | [Date] | Tracking ID receipt |
| Overflow faxed | [Date] | Fax cover and confirmation |
| IRS intake confirmed | [Date] | Acknowledgment email or letter |
Reality check, if payroll exports take longer than expected, do not stall the entire project. Lock your narrative, list the missing periods, and file quickly. You can send supplemental exhibits if the reviewer asks for them.
Correction action steps the IRS expects to see
Your schedule and narrative should show a clean sequence from discovery to deposit confirmations. The structure below works well for SIMPLE IRA VCP cases and fits the way Form 14568-D is organized.
Sequence your work with dated checkpoints
- Discovery and scope
- Note the failure types, list plan years, and identify affected participants.
- Pull plan clauses that applied in each year.
- Calculations and method
- Choose the earnings approach, actual returns or an approved proxy.
- Calculate missed deferral opportunity make‑ups, employer match or nonelective shortfalls, and any excess corrections.
- Execute corrections
- Deposit all corrective amounts with earnings to each person’s SIMPLE IRA.
- For excess amounts, process distributions with proper reporting.
- Verify and document
- Collect custodian confirmations and bank proofs.
- Reconcile totals to worksheets and list the final correction date.
- Prevent recurrence
- Update procedures, train staff, and add a control to catch the same issue early next time.
Handling missed deferral opportunity
When someone was denied the chance to defer, make a missed deferral make‑up using the schedule’s standardized approach. The form assumes a 3 percent deferral for estimating the base when no election existed, then you fund 50 percent of that amount, plus earnings through the deposit date. Document how you computed the base and show the period used for earnings. Keep the math simple enough for the reviewer to trace without your payroll system open.
Fixing employer match and nonelective shortfalls
Start with the plan formula that applied in each year, for example match up to 3 percent or 2 percent nonelective. Compute what should have been contributed, subtract what was posted, and fund the shortfall with earnings from the due date to the correction date. If employees never had a chance to defer, use the 3 percent assumed deferral base to compute the missed match. Show totals by year and by person.
Late deposits, excess amounts, and special cases
- Late deposits Calculate and deposit lost earnings to each affected SIMPLE IRA. Attach custodian confirmations and show the earnings method.
- Excess amounts Return excess deferrals or excess employer contributions with proper reporting. If a participant already took a distribution, document how you handled earnings to make them whole or how you corrected reporting.
- Closed or transferred SIMPLE IRAs If an account was closed, coordinate with the participant and the custodian to direct the corrective deposit to an active SIMPLE IRA or a permissible rollover destination. State what you did and include proof.
Quick win, batch your custodian confirmations by year and label them to match your worksheet tabs. The cleaner the trail, the faster the close.
Post‑approval monitoring that actually sticks
- Within 30 days of IRS approval, finish any remaining deposits, send participant notices that explain the fix, and save confirmations.
- Within 90 days, complete a mini audit. Confirm that the plan document and notices are up to date, payroll settings match the plan formula, and your remittance timing control is working.
- For months 3, 6, 9, and 12, review a one‑page checklist. Record the control owners, spot check a pay period, and confirm no late remittances.
- Keep your VCP file for six years. If the IRS asks later, you will have exactly what they need.
Required narrative attachments and enclosures
Use a simple checklist and do not skip signatures.
- Problem summary and chronology with dates
- Plan document or model form used in each failure year, for example 5304‑SIMPLE or 5305‑SIMPLE
- Participant list with amounts, by period
- Calculation worksheets that reconcile to totals
- Custodian confirmations and bank proofs
- Signed penalty‑of‑perjury statement if required
- Form 2848 or Form 8821 if applicable
- Form 8950 and fee details
- Index page, bookmarks, and clear file names
How Form 14568‑D aligns with Rev. Proc. 2021‑30
Think of the revenue procedure as your instruction manual and 14568‑D as your template. Section ordering in the procedure maps to the way the schedule is built. That is why you should:
- Keep the single PDF, non‑fillable format.
- Follow a clear, sequential narrative.
- Tie every number in your worksheets to a line on the schedule.
- Include the signatures that make your statements binding.
A quick Accountably note, only where it helps
If your internal team is buried in peak season, you can still meet tight VCP timelines with a disciplined delivery setup. At Accountably, we integrate trained offshore teams into your workflow with SOPs, standardized workpapers, and multi‑layer reviews, so pulling payroll, building worksheets, and compiling exhibits does not pull partners into all‑night sessions. Use us when structure and throughput matter, not for resume farming.
FAQs, direct answers in 2 to 4 sentences
Do I have to use Form 14568‑D, or can I just write a letter?
Use the form. The IRS designed 14568‑D to standardize SIMPLE IRA corrections in VCP. You can attach a narrative for details, but Schedule 4 is the expected format and it speeds review.
Who signs the penalty‑of‑perjury statement?
An individual authorized to sign for the plan sponsor, usually an officer or owner. Confirm authority under your governing documents and keep the signed statement in the same PDF as the forms.
Can I use SCP instead of VCP for SIMPLE IRA mistakes?
Sometimes. If the failure qualifies for self‑correction under EPCRS and you meet the timing and significance limits, SCP may be available. If the error is significant, long‑running, or you want formal IRS sign‑off, file VCP with 14568‑D.
How do I calculate earnings for missed amounts?
Use actual investment results if you can. If not, use an acceptable proxy listed in the current instructions and apply it consistently from the failure date to the correction date. Document the method and keep your math reproducible.
What if a participant closed their SIMPLE IRA?
Work with the participant and custodian to direct the corrective deposit to an active SIMPLE IRA or an eligible rollover destination. Explain what you did in your narrative and attach confirmations.
Do I need Form 2848 or Form 8821?
Use Form 2848 if you want a representative to negotiate, sign, and receive IRS communications. Use Form 8821 if you only want a person or firm to receive copies of correspondence. You can file both if roles differ.
How long does the IRS take to respond?
Plan for several weeks for intake, then additional time for review. Response times vary with season. Keep your package clean so the reviewer has what they need on the first pass.
What goes in the single PDF, and why non‑fillable?
All forms, narratives, worksheets, and evidence belong in one non‑fillable PDF so the reviewer can open, read, and archive it without field conflicts. Print to PDF, set the order, and bookmark sections for easy navigation.
A short case story, from backlog to approval
A 45‑person service firm realized in February that two payroll cycles from the prior spring never posted. The team was stuck between commitments and a short support staff. We helped them map failures by participant and period, use the schedule’s standardized methods for missed deferral and match, batch custodian confirmations, and assemble a clean single PDF with bookmarks. The reviewer accepted the math as filed and issued an approval letter without a second document request. The partner told me it was the first time a correction did not eat their entire weekend.
Quick checklist you can print
- Identify failure types, plan years, and affected participants
- Pull plan documents, amendments, and notices for the years at issue
- Choose earnings method and build worksheets that reconcile to totals
- Complete Form 14568‑D and any other schedules needed
- Prepare Form 8950, add Form 2848 or Form 8821 if applicable
- Assemble a single non‑fillable PDF with a clear index and bookmarks
- Upload on Pay.gov, pay the fee, and save the Tracking ID
- Send overflow by fax the same day, keep the confirmation
- Monitor for intake, answer questions quickly, and retain the full file for six years
Final thoughts and next step
If you follow the structure in this guide, your SIMPLE IRA VCP filing will read like a professional workpaper set, not a mystery novel. You will show what went wrong, who was affected, how you fixed it, and how you will keep it from happening again. If your team needs reliable production help to assemble the package, or you want standardized workpapers that cut partner review time, we can plug in without disrupting your tools or your templates. Either way, you now have a clear, human plan to get Form 14568‑D across the finish line.