Form 14568‑H – RMD VCP Guide and Checklist

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You are correcting missed or short RMDs, and you are showing the IRS your system is tight enough that it will not happen again.

This guide walks you through what to include, how to calculate make‑up amounts with earnings, where Appendix A, section .06 fits, and the small details that keep submissions moving. We reference current 2025–2026 IRS guidance, including SECURE 2.0’s updated RMD penalty and ages, so you are not relying on old rules.

Key Takeaways

• Use Form 14568‑H, Schedule 8 with Form 14568 to report late or insufficient RMDs under IRC §401(a)(9) through the Voluntary Correction Program, and file the VCP application with Form 8950 on Pay.gov, with Form 8951 only if an additional user fee payment is needed. Do not change the model form format.
• Schedule 8 is for affected participants only. If beneficiaries are also involved, use Form 14568 with narratives instead of 14568‑H. List each participant‑year on its own line.
• The RMD excise tax under §4974 is now generally 25 percent, reduced to 10 percent if corrected within the statutory correction window. VCP is where you request excise tax relief from the IRS.
• You cannot roll over RMDs or corrective RMD amounts. Document each shortfall, the life expectancy factor used, and earnings through the correction date.
• Expect 4 to 6 months from submission to receive your signed compliance statement. Build prevention procedures and attach them to your packet.

What Form 14568‑H Is And When To Use It

Form 14568‑H, Schedule 8, is the model schedule for late or insufficient RMDs in a VCP submission. You attach it to Form 14568, the model VCP Compliance Statement, and you initiate the case with Form 8950 on Pay.gov. Use the IRS model format as is, keep headings and fields intact, and add narratives and worksheets as attachments.

• Use 14568‑H when the failure is untimely or underpaid RMDs for participants.
• Do not use 14568‑H if beneficiaries are part of the failure set, and do not use it where plan benefits never commenced in a timely manner at the plan's normal retirement age or upon the participant's death. In those cases, disclose on Form 14568 with a clear written narrative.

What VCP gives you that SCP does not is the ability to request waiver of the participant excise tax for missed RMDs while you correct the plan failure and secure an IRS compliance statement (relief is not automatic, you must affirmatively check the Section III A. box on 14568‑H and provide the required owner-employee disclosure and explanation). That written agreement matters on audit and with custodians.

Why this matters after SECURE 2.0

The SECURE 2.0 Act changed two things you must reflect in your packet. First, the penalty on missed RMDs moved from 50 percent to 25 percent, and down to 10 percent if corrected within the correction window. Second, the required beginning date is age 73 for individuals who reach 72 after December 31, 2022 and 73 before January 1, 2033. Make sure your narratives and worksheets use the right penalty and the right age rules.

Eligibility, Scope, And What The IRS Expects

You are eligible to use 14568‑H when you are correcting missed or short RMDs under §401(a)(9) and proposing Appendix A, section .06 corrections. Your packet should prove three things, you identified every affected participant, you listed each failure year separately, and your correction math plus earnings is complete and reasonable.

The “participant‑year” rule

The IRS wants you to show each participant for each year on its own line in Section I of 14568‑H. Then show the count of affected participants and the total missed RMD dollars for each year. This is a common return‑for‑incompleteness issue when firms aggregate years on one line.

When VCP fits better than SCP

Some RMD failures can be self‑corrected, but SCP cannot waive a participant’s excise tax. If you need excise tax relief, or if the failure is significant and outside SCP, use VCP and 14568‑H.

Quick note on form versions

Form 14568-H was last revised June 2018 (Rev. 6-2018) and remains the current version of the form as of tax year 2025; the IRS maintains staff procedures for VCP schedules in the Internal Revenue Manual. Schedule 8 remains the RMD schedule, and reviewers check that you did not add logos or change the model text. Keep the format pristine.

The RMD Rules You Must Model Correctly

Your math lives or dies on three inputs, the prior year December 31 balance, the correct life expectancy factor for that RMD year, and the right required beginning date. SECURE 2.0 moved the RBD to age 73 for many participants, and the law creates edge cases by birth year. Double check which table you used, single life, uniform lifetime, or joint life where the spouse is more than ten years younger and the sole beneficiary.

• Lifetime RMDs do not apply to in‑plan Roth accounts beginning in 2024. If your failure year is 2024 or later and the missed amount is tied to an in‑plan Roth, confirm whether an RMD was required at all before you calculate a shortfall.
• RMDs and corrective RMDs are not eligible for rollover. Do not try to push them through as 60‑day rollovers. The FAQs and Publication 590‑B say no.

If your numbers do not sit on the correct RBD and life table, the rest of the packet will not matter.

Quick‑Start Checklist, Assembling Your Form 14568‑H VCP Packet

You want momentum, not second guesses. Start with a simple packet layout that your reviewer can follow at a glance. Keep the model forms clean, attach your narratives and worksheets, and label every exhibit so the participant‑year and the math line up.

Required Forms Checklist

Use this as your cover prep before you draft a single narrative.

• Form 8950, VCP application on Pay.gov, confirm correct plan sponsor info.
• Form 14568, Model VCP Compliance Statement, unchanged format.
• Form 14568‑H, Schedule 8, one line per participant‑year.
• Any other Schedules A through I that apply to your filing facts.
• Form 8951 only if a fee adjustment is required by the current user fee table.
• Authorization, Form 2848 for representation or Form 8821 for information‑only access.
• Exhibits, participant‑year worksheets, correction proofs, prevention procedures.

A one‑page index helps IRS staff route questions to the right page fast. Include contact names, titles, phones, and emails that actually pick up.

RMD Failure Documentation

Treat this like an audit trail that anyone can re‑run.

• Identify each participant by name or ID and list each failure year on its own line.
• Show required RMD, actual paid amount, and the shortfall for the year.
• Attach your factor source and method, uniform lifetime, single life, or joint life if the spouse is more than ten years younger and the sole beneficiary.
• Include earnings from the original due date through the correction date, with the rate and compounding spelled out.
• Add evidence of corrective distributions, payment confirmations, and withholding entries.
• File participant notices and correspondence you sent for the correction.
• Cross‑reference every attachment to the matching participant‑year line on Schedule 8.

Keep your math sheets simple. A consistent header, participant ID, year, account balance date, factor used, required RMD, paid, shortfall, earnings, total corrective amount.

Prevention Procedures Summary

You are not done until you explain how you will avoid the same mistake next season.

• Notices, send initial RMD notices 90 days before year end, with 30‑day and 10‑day reminders for open cases.
• Timing, process elections inside 15 business days and escalate any blocker at day 10.
• Roles, the plan administrator owns oversight, the recordkeeper runs calculations and exception reports, payroll or the custodian executes distribution instructions.
• Monitoring, run a quarterly reconciliation of census, age, and balances, then a year‑end exception report for anyone nearing the required beginning date.
• Documentation, keep proofs for six years, store tables and factor sources with the worksheets.
• Training, require an annual RMD refresher for your team and vendors, include change‑control for table or system updates.

Eligibility Focus, Evidence, And Pitfalls

Use this quick table to keep your packet tight.

Eligibility focus	Evidence required	Common pitfall
Participant‑year scope	Separate line for each year per participant	Aggregating all years on one line
Amounts missed	Worksheets that tie to account balance and factor	Using estimates rather than math
Period and divisors	Cited table and method, with the date used	Inconsistent factors across years

Required Forms And Attachments, Flow That Reviewers Prefer

Give reviewers a packet that answers questions in the order they think. Here is a flow that works well.

• Cover letter with a two‑paragraph story, what failed, how you found it, what you fixed, and how you will prevent a repeat.
• Form index with page numbers and exhibit labels.
• Form 8950 confirmation and filing details.
• Form 14568, unaltered.
• Form 14568‑H, Schedule 8, completed and signed if signature is requested by the current form version.
• Participant‑year worksheets in the same order as Schedule 8.
• Proof of corrective distributions and withholding.
• Excise tax relief narrative and calculations if requested.
• Prevention procedures with roles and timelines.
• Authorization forms, Form 2848 or Form 8821, if used.

Think like a reviewer, can someone confirm every number without emailing you. If yes, you are ready to file.

Calculating Missed RMDs And Make‑Up Amounts

Here is a clear, repeatable method you can defend.

• Step 1, pull the account balance as of December 31 of the prior year for each failure year (for multi-year corrections, reduce that actual balance by all prior years' missed RMDs before you divide, otherwise the year N RMD is computed against a balance that still includes undistributed prior shortfalls).
• Step 2, select the correct life expectancy factor for that RMD year, single life, uniform lifetime, or joint life where the spouse is more than ten years younger and the sole beneficiary.
• Step 3, compute the required RMD for the year, then subtract the amount actually paid in that year. The result is the shortfall.
• Step 4, compute earnings on the shortfall from the RMD due date to the correction date using a reasonable rate you can document, then show compounding if used.
• Step 5, add shortfall and earnings for the corrective distribution.
• Step 6, prepare participant communication, the distribution will be taxable, and it is not eligible for rollover.

If a participant has multiple missed years, keep each year separate on Schedule 8. Your worksheets can total by participant for payment logistics, but your schedule must respect the year‑by‑year rule.

Worked Examples You Can Mirror

Numbers tell the story fast. Here are simple examples you can adapt. Replace placeholders with your real inputs, then attach the worksheets behind Schedule 8.

Defined Contribution Example

Participant A missed part of the 2019 RMD and all of 2020.

Participant	Year	Account balance date	Factor used	Required	Paid	Shortfall
A	2019	12‑31‑2018	Uniform lifetime 25.6	12,500	8,300	4,200
A	2020	12‑31‑2019	Uniform lifetime 24.7	13,000	0	13,000

Earnings method, simple annual rate at X percent from each due date to the correction date. You can use monthly compounding if your plan’s recordkeeping supports it. Show the rate, the time period, and the math. Then list the total make‑up payment by year and the combined total if you plan to issue one check.

Participant letter, explain the reason, the make‑up amounts, the tax treatment, and provide contact details for questions.

Defined Benefit Example

Participant B’s annuity started late. For each shortfall year, compute the additional payment representing loss of use using the plan's own written terms for actuarial equivalence (interest rate and mortality assumptions as defined in the plan document), not the DC-style earnings method or a generic IRS-published rate. Attach actuarial support that shows present value and any required adjustment to bring the benefit current. The schedule still uses one line per participant‑year with the dollar shortfall for that year.

Documentation Your Reviewer Will Expect

• A copy of the factor tables or a link citation that matches the years used.
• Screenshots or exports showing the account balance dates and balances.
• Payment confirmations for make‑up distributions and withholding.
• A short memo on how you set the earnings rate and compounding.
• A prevention plan with roles and SLAs so this does not happen again.

Keep your math human, someone should be able to check your numbers with a handheld calculator.

Completing The Participant RMD Failure Table On 14568‑H

The table is simple, your discipline is what makes it work.

• Enter a unique line for each participant and each failure year.
• Use the calendar year for the RMD year and tie it to the required beginning date as needed.
• Record the required amount, the actual amount distributed, and the shortfall (Section I's 'Total Amount of Missed Required Minimum Distributions' column excludes earnings; report the raw missed RMD only and put earnings or loss-of-use adjustments in Section II).
• Reference the exhibit number for the worksheet that supports that line.
• Confirm totals at the bottom and ensure they match your narratives.

Tie‑Out Checklist Before You File

• Every line has a matching worksheet.
• Worksheet totals equal your proof of payment totals.
• Names or IDs match across forms, worksheets, and notices.
• Authorization forms list the same contact names as your cover letter.
• Prevention controls call out who owns what, with dates that make sense.

If you must choose between fancy spreadsheets and plain proof, pick plain proof. Reviewers reward clarity.

DC Versus DB Differences That Matter On Schedule 8

Treat DC plans as account math and DB plans as actuarial math.

• DC plans, compute missed RMDs from the adjusted account balance (the prior year actual balance, determined under Treas. Reg. §1.401(a)(9)-5 Q&A-3, reduced by all prior years' missed RMDs) divided by the correct distribution period factor. Track each year, show earnings, and prove distribution.
• DB plans, attach actuarial determinations of present value or benefit adjustments and show how you corrected each late or short payment.
• In both cases, give the IRS a year‑by‑year trail and prevention controls that can be tested.

Requesting Excise Tax Relief For Late RMDs

If you are asking for excise tax relief on missed RMDs, show that you corrected promptly and completely, and give the IRS a clean story.

What To Include

• Identify each participant and each failure year involved in the request.
• Compute the excise tax by year, then explain why relief is appropriate based on your facts.
• Include proof of corrective distributions and earnings payments.
• Explain the cause, discovery, and the specific fixes you implemented.
• Address participant impact, any reimbursements, and how you handled tax reporting.

Write this as if you were explaining it to a plan participant. If they would understand and accept your reasoning, your IRS reviewer probably will too.

Common Excise Relief Evidence

• Detailed timeline from failure to discovery to correction.
• Copies of exception reports and the final cleared list.
• Preventive steps that trigger earlier in the year than the failure happened.

Appendix A, Section .06, How To Frame Your Correction

Appendix A, section .06 is the heart of your correction method for RMD failures. Your job is to prove you used it correctly.

Eligible RMD Failures

You are dealing with late or short required minimum distributions under the plan, not a plan document failure. Identify the population, list every participant‑year, and keep the scope limited to the years and people you can prove.

• You list each missed or short RMD by participant‑year.
• You include the distribution periods and the amounts.
• You attach the calculations and the evidence of payment.
• You request excise relief if you need it.

Correction Calculation Rules

• Compute the missed RMD for each year.
• Apply earnings from the original due date to the actual correction date, using a reasonable and documented rate.
• Sum shortfall plus earnings for the make‑up amount.
• Keep DB cases supported with actuarial work and present value where needed, and pull the additional payment rate from the plan's written terms for actuarial equivalence (not a generic IRS-published rate or AFR).

Procedural Safeguards The IRS Wants To See

• A participant‑year RMD ledger that lets anyone replicate the totals.
• Review checkpoints, who verified the factor, who verified the balance, who signed off on the amount.
• Issue logs, how exceptions were cleared and by whom.
• Cross‑references on Forms 8950, 14568, and 14568‑H so the same people and dates appear throughout.

Show your work like a math class, it reduces questions and speeds approval.

Operational Fixes To Prevent Future RMD Misses

Corrections get you compliant, systems keep you compliant.

Controls That Hold Up In Busy Season

• Automation, configure your recordkeeping system to identify RMD‑eligible participants by September, then refresh in December.
• Notices, send 90‑day, 30‑day, and 10‑day reminders and record confirmations.
• Reconciliations, tie the eligible list to HR census and custodial records each quarter.
• Exception reporting, escalate any open case older than ten business days.
• Vendor SLAs, require specific turnaround times from TPAs and recordkeepers and test them.

Common 14568‑H Filing Mistakes And How To Avoid Them

Avoid the easy errors that slow everything down.

• Aggregating participant‑years, list each year separately for each person.
• Using estimates, provide the actual balance date, factor, and math.
• Missing narratives, include cause, correction, and prevention.
• Altering model forms, keep Form 14568 and Schedule 8 unaltered.
• Signature gaps, confirm that every required signature is present and current.
• Loose exhibits, label and cross‑reference every worksheet and proof of payment.

Pre‑File Quality Control

• Independent review, have someone not involved in the math check every worksheet against Schedule 8.
• Totals test, worksheet totals must equal the payment evidence totals.
• Timeline test, your prevention steps should start before the month when the original failure occurred.

Where Accountably Helps Without Losing Control

If your internal team is buried, you still need precision and speed. This is where a disciplined offshore delivery partner can help without diluting control.

• We integrate trained offshore accountants into your workflow, inside your systems and templates.
• We standardize workpapers, file naming, and version control so reviewers spend less time hunting for context.
• We staff review layers, preparer to senior to quality to final, with turnaround SLAs and live tracking.
• We work in the tools you already use, QuickBooks, Xero, UltraTax, CCH Axcess, ProConnect, Lacerte, Drake, Thomson Reuters, Canopy, Karbon, TaxDome, Suralink, and JetPack.

Mentioning Accountably here is intentional, it is about delivery discipline, not resumes. If you can handle the packet internally, use this guide and go. If you want a production engine that protects review time and quality, we can help.

Final Review Checklist Before You Hit Submit

Print this section and mark each box.

• Forms, Form 8950, Form 14568, and Form 14568‑H are complete, current, and unaltered.
• Schedule 8, one line per participant‑year, totals match exhibits.
• Worksheets, every line on Schedule 8 has a matching worksheet with balance date, factor, required RMD, paid, shortfall, earnings, and total.
• Proofs, payment confirmations and withholding tie to worksheet totals.
• Excise relief, if requested, includes clear math and a credible prevention plan.
• Prevention, controls list roles, timelines, SLAs, and monitoring steps.
• Authorization, Form 2848 or Form 8821 is attached if used.
• Index, page numbers and exhibit labels make the packet easy to scan.

Common Mistakes We See Every Season

These are the patterns reviewers flag most often when 14568-H packets come back for incompleteness. Each one traces to a shortcut in the Section I table, the make-up math, or the supporting narrative.

Reusable Checklists

These checklists are copy-paste ready for your firm SOP, your case file, or your project tracker. Each one is shaped around what reviewers expect to see in a clean 14568-H packet.

Keep 14568-H Season From Stalling

VCP discoveries cluster, and they cluster badly. Most 14568-H cases surface during year-end RMD reviews, plan audits, or recordkeeper conversions, and a single discovery often pulls three or four years of recalculations across dozens of participants into the same week. The form text itself was last revised June 2018 (per the IRS Form 14568-H instructions), so every active packet now requires the preparer to translate between the form's older 50 percent language and the current 25 percent excise tax under IRC §4974 (or 10 percent inside the correction window), per the SECURE 2.0 Act of 2022.

When the discovery list grows faster than the in-house team can clear it, the temptation is to summarize the math. Reviewers do not accept summaries. The packet has to show each participant-year on its own line, an adjusted-balance computation that subtracts prior shortfalls, an earnings rate the plan can defend, and a Section IV narrative that closes the loop on both root cause and prospective controls.

• Lock the Section I worksheet on the year row, not the participant row, so multi-year failures generate the right participant counts and the right missed-RMD totals.
• Maintain a single DC earnings-rate policy (plan trust rate or a stated alternative) and apply it from each failure date to the corrective distribution date.
• For DB plans, paper the plan's actuarial equivalence assumptions (interest rate and mortality table) on a coversheet so the §436(d) decision and additional-payment math are auditable on their own.
• Keep a Section V AFTAP certification template ready for every 'No' answer to the §436(d) restriction question, even when the certification looks routine.
• Pre-build the Section IV root-cause and prevention paragraphs around the recordkeeper alert, calendar lock, and review SLA you will actually run going forward.

When the packet load runs past in-house capacity, the structured production work moves to Accountably. We run the Section I worksheet, the per-participant make-up math, the earnings file, and the Section IV prevention narrative through documented SOPs so the reviewer on your side signs the packet instead of building it from scratch. See how the tax delivery workflow runs when 14568-H volume is the bottleneck.

FAQs

How do I pick the right life expectancy factor?

Use the factor that applies to the RMD year and the participant’s situation. For most living participants, the uniform lifetime table applies. Use joint life only if the spouse is more than ten years younger and the sole beneficiary. Document the table you used and the date you pulled it.

How do I compute earnings on missed RMDs?

Pick a reasonable rate you can support with plan records or policy, then apply it from the original due date to the correction date. Be explicit about simple or compound treatment and keep it consistent across the population unless facts require a change.

What if the participant is deceased?

If a beneficiary should have received a death‑related distribution, do not put that case on 14568‑H. Disclose the failure in your narratives on Form 14568 and document the beneficiary correction and timing rules that apply.

Can corrective RMDs be rolled over?

No. Corrective RMDs are taxable distributions. Communicate this clearly to participants and reflect it in your tax reporting.

How fast will the IRS respond?

Plan for several months from a complete submission to a signed compliance statement. Well‑organized packets, clean math, and clear prevention steps reduce follow‑up.