The fix was not another application, not a paper check, just Form 8951 on Pay.gov, tied to the same VCP control number, and the panic was over in minutes. If you have an open EPCRS VCP case and discover that the original user fee was short or declined, Form 8951 is the tool you use to pay only the additional amount, nothing more and nothing less.
The IRS confirms that Form 8951 is for additional payments on open VCP submissions and that filing is electronic through Pay.gov.
Key Takeaways
- Form 8951 is only for an additional user fee on an existing, open EPCRS VCP case. Do not use it for a brand‑new VCP filing.
- You file and pay through Pay.gov in one session, then save the receipt and tracking ID. Paper payments are not accepted.
- VCP fees are based on total plan assets, not participant counts, for submissions made on or after January 1, 2020. Use the asset brackets to determine what you still owe.
- Use your VCP control number on Form 8951. In IRS systems this is the RCCMS work unit number for the case.
- If your original ACH payment was declined and marked retired, do not resubmit Form 8950. Use Form 8951 to make a new payment for the same case.
What Form 8951 does, and what it does not do
Form 8951 has a narrow job. It lets you pay an additional VCP user fee on an open case that already exists at the IRS. You are not reopening your application, you are not amending the failures or corrections, and you are not changing eligibility terms. You are bringing your user fee up to the correct amount and linking that payment to the same VCP control number so the specialist can continue processing your case. The IRS “About Form 8951” page states that, as of April 1, 2019, the submission and payment must be done electronically through Pay.gov, using the site’s search to find “8951.”
Here is the boundary line that prevents costly missteps:
- Use Form 8951 when the IRS tells you additional fee is due, or when you discover you underpaid.
- Do not use Form 8951 for an initial VCP application, use Form 8950 for that workflow.
The fastest path to closing the loop is simple, pay only the difference through Pay.gov with the correct control number on Form 8951.
Who should care about Form 8951
If you are a plan sponsor, ERISA counsel, recordkeeper, or CPA firm managing VCP submissions, you should know this form cold. Many user fee issues are operational, not technical. Someone typed the wrong asset number, selected the wrong plan type, or the bank declined the ACH. The IRS specifically instructs filers that when the initial ACH is declined and labeled retired, you should not submit a new Form 8950, you should use Form 8951 to make the replacement payment on the original case. That one detail saves days of confusion.
Why fees are asset‑based now, not participant‑based
Search engines still surface old PDFs that mention participant counts. Ignore them for today’s filings. For submissions made on or after January 1, 2020, VCP fees are based solely on total net plan assets, including SEPs, SARSEPs, and SIMPLE IRAs. The IRS publishes the three‑tier asset schedule and keeps the page current. This is the schedule you use to confirm whether your original payment was short, and it is the schedule that drives any additional amount you pay with Form 8951.
Quick compliance note and dates you can rely on
- The IRS “About Form 8951” page was reviewed or updated on January 17, 2025, and it confirms electronic Pay.gov submission, single‑session filing, and the Internet Explorer display note.
- The IRS VCP fees page was reviewed or updated on August 26, 2025, and confirms asset‑based fees for submissions on or after January 1, 2020.
This guide reflects those dates. Always check the IRS pages before you file, then document the page titles and access dates in your case file. If you need a primary reference for the EPCRS framework itself, Rev. Proc. 2021‑30 in IRB 2021‑31 remains the operating foundation for VCP, with user fee amounts set annually by the applicable revenue procedure and the VCP fees page.
Fee structure, examples, and how to compute only the difference
You do not guess the additional amount. You recompute the correct VCP user fee from the asset table, then subtract what you already paid, and you remit the difference via Form 8951. The IRS fee table for submissions made on or after January 1, 2020 appears below. Always confirm the current table before filing.
VCP user fees based on total net plan assets
| Plan assets | VCP user fee |
| 0 to 500,000 | 1,500 |
| Over 500,000 to 10,000,000 | 3,000 |
| Over 10,000,000 | 3,500 |
The IRS notes exceptions, for example orphan plans may have a waived fee, group submissions have their own structure, and 457(b) plans are handled outside VCP. These are edge cases, so confirm your facts before you apply them.
Worked examples you can mirror
- Example 1, straightforward shortfall Your plan assets are 2.8 million, so the fee is 3,000. You originally paid 1,500 when you filed Form 8950. You owe 1,500 more. Use Form 8951 to pay 1,500, enter your VCP control number, and save the Pay.gov receipt.
- Example 2, declined ACH, same day fix Your ACH for 3,000 was declined and marked retired. Do not submit another 8950. Use Form 8951 on Pay.gov to pay 3,000 to the same control number. This aligns with the IRS reminder for “retired” ACH cases.
- Example 3, fee tier change after correcting assets You discover the asset figure entered on Form 8950 omitted a subsidiary trust. True assets are 11.4 million, not 9.9 million. The correct fee is 3,500. You originally paid 3,000. Pay the 500 difference with Form 8951. Document why the asset figure changed in the case memo and include support with your file.
What control number to use, and where to find it
On Form 8951 you will enter the VCP control number so the payment hits the correct case. The IRS Internal Revenue Manual explains that the control number is the RCCMS work unit number assigned to your VCP submission. If your case was filed through Pay.gov using Form 8950, the Pay.gov tracking ID on your original receipt ties back to that control. Keep both numbers in your records.
Documentation to keep in your file
- Screenshot or PDF of the current IRS VCP fee page with access date.
- Pay.gov confirmation that shows the Form 8951 payment and tracking ID.
- Short memo that explains the reason for the additional payment, for example corrected assets or declined ACH.
- Any correspondence from the IRS specialist requesting an additional amount. The IRM even provides sample language that a specialist may use when asking you to pay the balance and to send the Pay.gov receipt.
Good files win audits. Save your Pay.gov receipt, the control number, and the page titles and dates for every IRS reference you used.
A quick word on sanctions and exceptions
The user fee is not always the final word. In limited cases, for example certain SEP or SIMPLE IRA situations or failures that involve section 72(t), the IRS may impose a closing agreement sanction above the standard VCP fee. This does not change how you use Form 8951, it only changes the total you might owe if the IRS communicates a different amount.
Step‑by‑step, filing Form 8951 on Pay.gov without headaches
The process is simple if you follow the sequence exactly. The IRS and Pay.gov outline the path clearly, and doing it in one sitting prevents session timeouts and entry errors.
1) Create or sign in to your Pay.gov account
- Register a Pay.gov account with a monitored business email, then sign in.
- Multi‑factor authentication helps avoid lockouts during the payment step.
- Keep the session active while you complete the form and payment in one go. The IRS states that Form 8951 must be submitted electronically on Pay.gov.
2) Find the form by searching “8951”
- Use the Pay.gov search box, type 8951, then select “Additional Payment for Open Application for Voluntary Correction Program (VCP).”
- Confirm you see the steps, Before You Begin, Complete Agency Form, Enter Payment Info, Review and Submit, and Confirmation.
3) Gather the three things you cannot file without
- Your VCP control number, the RCCMS work unit number for the case.
- The correct user fee amount based on plan assets and the difference still due.
- Payment method, ACH, debit, or credit card are accepted.
4) Complete the online Form 8951
- Enter plan sponsor name, EIN, plan name, and the control number.
- Input the additional fee amount only, do not enter the full fee again unless instructed.
- Review entries carefully, then proceed to payment. The Pay.gov page confirms that Form 8951 is meant for an additional user fee on an existing VCP case, commonly when an IRS employee instructs you to pay the difference.
5) Authorize payment and save your proof
- Approve the payment and wait for the confirmation screen.
- Save the Pay.gov receipt and tracking ID, the specialist will need it to finish processing. The IRM notes that the specialist cannot close the case until certain Pay.gov documents for the new payment are received.
Browser and display troubleshooting
- Chrome, Firefox, and Edge usually display the form correctly.
- If the form appears compressed in Internet Explorer, turn on Compatibility View per Microsoft’s guidance. This is an IRS‑acknowledged quirk.
- If you hit a CloudFront or timeout error, sign out, clear cache, sign back in, and try again later. If issues persist, use the contact info on the Pay.gov form page.
Quick role checklist you can copy
| Role | What to do before filing | What to save after filing |
| Plan sponsor or POA | Confirm asset figure and fee tier, collect control number | Pay.gov receipt, tracking ID, copy of IRS email or letter |
| CPA or ERISA counsel | Review math and narrative, draft short memo for file | PDF of IRS VCP fees page with access date |
| Operations staff | Verify Pay.gov login works and payment method is ready | Internal ticket closed with receipt attached |
One session, one receipt, one clean audit trail, that is how you prevent avoidable back‑and‑forth with the IRS.
Common mistakes, operational fixes, and how to avoid repeat work
The mistakes we see most often
- Wrong asset number entered on Form 8950, which miscalculates the fee tier. Fix it, then pay the difference with Form 8951.
- Resubmitting a new 8950 after a declined ACH. The IRS tells you to use 8951 instead so the case stays intact.
- No control number on the 8951 payment, which delays posting. Use the RCCMS work unit number.
- Missing proof, no Pay.gov receipt attached to the case file, which stalls closure. Save and share the receipt with the specialist.
Process habits that save time
- Maintain a one‑page SOP for VCP payments that includes the current asset fee table link, who approves numbers, and where to store receipts.
- Add a pre‑submission check, validate plan assets against the most recent valuation and custodial statements.
- Centralize the VCP control number and Pay.gov tracking IDs in your practice management system so handoffs are clean.
FAQs, quick answers you can use
Do I use Form 8951 for a brand‑new VCP submission?
No. New submissions use Form 8950 on Pay.gov, which also collects the initial user fee. Form 8951 is only for an additional payment on an existing open case.
What payment methods can I use with Form 8951?
Pay.gov accepts ACH, debit, and credit cards for Form 8951. You must be signed in to submit the payment.
Which control number goes on Form 8951?
Use the VCP control number for the case, which the IRS IRM describes as the RCCMS work unit number already assigned to the submission. If you filed through Pay.gov, your original Pay.gov tracking ID ties back to that case.
How fast does the payment post and can the case close without it?
ACH can take 24 to 48 hours to clear. The IRM notes the specialist cannot close the VCP case until the Pay.gov deposit documents tied to your payment are received and reviewed.
Are VCP fees still based on participants?
No. For submissions made on or after January 1, 2020, VCP fees are based on total plan assets. Check the current fee page before you file.
Can the IRS ask for more than the user fee?
In limited situations, for example certain SEP or SIMPLE IRA cases or failures involving section 72(t), the IRS can impose a closing agreement sanction above the standard fee. Follow your specialist’s instructions if that applies.
A short note for CPA firms that juggle deadlines
If underpaid fees, declined ACHs, or missing receipts keep popping up, it is usually a delivery issue, not a knowledge gap. Standard operating procedures, structured workpapers, and review gates stop these mistakes before they reach the IRS. If you need disciplined capacity during peak season so fees, filings, and receipts are handled the same way every time, our team at Accountably integrates trained offshore staff into your workflow with SOPs, layered reviews, and Pay.gov checklists that protect partner time and client trust. Use this when you want capacity without chaos, and only where it genuinely helps your operations.