Form 8951 – VCP User Fee for EPCRS Submissions

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Most Form 8951 questions start with a note from an IRS Voluntary Compliance specialist asking for an additional user fee on a VCP case that is already open, and the worry is that a finished correction will stall over one payment. Form 8951 is what transmits that user fee, filed electronically on Pay.gov as an attachment to Form 8950.

The form no longer prints the fee amount, so you confirm the current figure in the annual Employee Plans revenue procedure before paying. The fee is based on the participant count from Line 5, taken from the most recently filed Form 5500. To add a fee to an open case, check the box on Line 6 and enter the nine-digit VCP case number so the payment ties back to the right submission.

Key Takeaways

• Form 8951 transmits the VCP user fee for an EPCRS submission and is attached to Form 8950. Use Line 7 or Line 8 for the initial general or reduced fee, and Line 6 only to add a fee an IRS employee requests on an open case.
• 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 the number of plan participants reported on Line 5, taken from line 6(f) of the most recently filed Form 5500. Confirm the current fee against the annual Employee Plans revenue procedure, since the amount is no longer printed on the form.
• When you add a fee on Line 6, enter the nine-digit VCP case number assigned to your submission so the payment ties back to the correct case.
• If a payment does not go through, do not resubmit Form 8950. Follow the IRS specialist's instructions and use Form 8951 to convey the fee for the same open case.

What Form 8951 does, and what it does not do

Form 8951 carries the user fee for a VCP submission. Attached to Form 8950, it conveys the initial general or reduced fee on Line 7 or Line 8, and Line 6 is used to pay an additional fee an IRS employee requests on an open case. 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 case number so the specialist can continue processing your case. Per the Form 8951 instructions, the form is filed electronically only on Pay.gov, so the submission and payment are handled there rather than by mailing a paper check.

Here is the boundary line that prevents costly missteps:

• Use Line 6 of Form 8951 to pay an additional fee only when an IRS employee in Voluntary Compliance requests it. Once a VCP submission has been filed, do not send additional payments for any fee matter unless the IRS has given you specific instructions to do so.
• Form 8950 is the VCP application; attach Form 8951 to it to convey the user fee, including the initial fee on Line 7 or Line 8.

The fastest path to closing the loop is simple, pay only the requested amount through Pay.gov with the correct nine-digit VCP case number on Line 6 of 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 participant count, selected the wrong plan type, or the payment did not clear. When a payment fails on an open case, you generally do not start over with a new Form 8950, you follow the IRS specialist's instructions and use Form 8951 to convey the fee for the same case. That one habit saves days of confusion.

How the VCP user fee is determined

The general user fee is based on the number of plan participants, taken from line 6(f) of the most recently filed Form 5500. The general user fee for a section 401(a) or 403(b) plan is based on the number of plan participants; SEP, SARSEP, and SIMPLE IRA plans use the reduced fee on Line 8(c). The IRS publishes the current participant-based fee figures in the annual Employee Plans revenue procedure and keeps the VCP fees page current. This is the schedule you use to confirm whether your original payment was short, and it is the figure that drives any additional amount you pay with Form 8951.

Quick compliance note and where to confirm the fee

• The IRS “About Form 8951” page confirms that the form is filed electronically only on Pay.gov, so plan to submit and pay there.
• The IRS Voluntary Correction Program fees page points to the current user fee, which is set in the annual Employee Plans revenue procedure rather than printed on the form.

Always check the IRS pages before you file, then document the page titles and access dates in your case file. Beginning in 2017 and each year thereafter, VCP user fees are published as part of an annual Employee Plans revenue procedure, so refer to the revenue procedure in effect at the time you file your submission to determine the correct user fee.

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 current Employee Plans revenue procedure for your participant count, then subtract what you already paid, and you remit the difference via Form 8951. The general user fee is based on the number of plan participants, and the current amount is published in the annual Employee Plans revenue procedure. Always confirm the current table before filing.

VCP user fees based on the number of plan participants

The general user fee for a section 401(a) or 403(b) plan is keyed to the number of plan participants reported on Line 5, taken from line 6(f) of the most recently filed Form 5500. The IRS no longer prints these amounts on Form 8951, so confirm the current figure in the annual Employee Plans revenue procedure in effect when you file, then enter it on Line 7 (or Line 8 if a reduced or alternative fee applies).

The IRS notes exceptions, for example orphan plans may have a waived fee (though that waiver is discretionary and must be requested in writing, not granted automatically), group submissions have their own structure, and 457(b) plans use Line 8(f), where no payment is due at the time of filing and any sanction is set when the closing agreement is signed. These are edge cases, so confirm your facts before you apply them.

Worked examples you can mirror

• Example 1, straightforward shortfall. Suppose the current revenue procedure sets a higher fee for your participant count than the amount you paid when you filed Form 8950. Use Form 8951 to pay only the difference, enter your nine-digit VCP case number on Line 6, and save the Pay.gov receipt.
• Example 2, a payment that did not clear. If your original payment was returned, do not start over with a new Form 8950. Follow the IRS specialist's instructions and use Form 8951 to convey the fee for the same open case number.
• Example 3, fee tier change after correcting the count. You discover the participant figure entered on Form 8950 was understated. Recompute the general user fee for the corrected participant count using the current revenue procedure, subtract what you already paid, and pay only the difference with Form 8951. Document why the figure changed in the case memo and include support with your file.

What case number to use, and where to find it

When you add a fee on Line 6, you enter the nine-digit VCP case number assigned to your submission so the payment hits the correct case. If your case was filed through Pay.gov with Form 8950, keep your original Pay.gov receipt and case number together in your records so you can match the payment quickly.

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, since you should not send additional fee payments unless the IRS has specifically instructed you to do so.

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 8951 payment on Pay.gov

• Use the Pay.gov search box, type 8951, and select the Form 8951 VCP user fee payment.
• Work through the on-screen steps in order so nothing is skipped before you submit.

3) Gather the three things you cannot file without

• The nine-digit VCP case number for your submission.
• The correct user fee amount based on the number of plan participants, and the difference still due if you are topping up.
• A working Pay.gov payment method you are ready to use.

4) Complete the online Form 8951

• Enter the plan sponsor name (Line 1), EIN (Line 2), plan number (Line 3), and plan name (Line 4).
• If you are paying only an additional fee an IRS employee requested, check the box on Line 6, enter that amount and the nine-digit VCP case number, and do not re-enter the original Line 7 or Line 8 fee.
• For the initial submission, enter the general fee on Line 7, or the applicable reduced or alternative fee on Line 8 if your plan qualifies. Form 8951 carries the user fee when it is filed with Form 8950.

5) Authorize payment and save your proof

• Approve the payment and wait for the confirmation screen.
• Save the Pay.gov receipt and case number, since the specialist will need confirmation of the payment to finish processing the case.

If the form or page will not load

• Use a current, supported browser so the Pay.gov form displays correctly.
• If you hit a timeout or display error, sign out, clear the cache, sign back in, and try again. 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 participant count and fee, collect the VCP case number	Pay.gov receipt, case number, 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

Most Form 8951 problems I see are operational, not technical. The same handful of slip-ups show up across plan sponsors and firms, and each one is easy to design out of your process.

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.

Reusable Checklists

These checklists are copy-paste ready for your firm SOPs, so the same VCP fee steps happen the same way on every case.

Keep 8951 Season From Stalling

Form 8951 work rarely arrives on a tidy calendar. It lands whenever an IRS Voluntary Compliance specialist asks for an additional user fee on an open VCP case, which means it competes with whatever else is on the desk that week. The IRS Paperwork Reduction Act notice for Form 8951 estimates about 3 hours 45 minutes to prepare the form and another 2 hours 39 minutes just to learn the rules, and a single mis-keyed case number or an unconfirmed fee can freeze an otherwise finished correction.

The way to keep these cases moving is process, not heroics. When the steps for confirming the fee, completing Line 6, and saving the Pay.gov receipt are standardized, the additional payment stops being a surprise and becomes a short, repeatable task.

• Pull the nine-digit VCP case number from the original Form 8950 or Pay.gov record before anyone touches Line 6.
• Confirm the current user fee against the annual Employee Plans revenue procedure instead of an older printed schedule.
• Complete only Line 6 for an additional fee and leave the original Line 7 or Line 8 entry untouched.
• Keep one Form 8951 and one payment per plan, since each plan needs its own submission.
• File the Pay.gov confirmation and tracking ID to the case the same day, so the specialist can close without chasing proof.

When VCP fee work stacks up against everything else, the answer is reliable capacity that runs the same playbook every time. Our tax execution team integrates trained offshore staff into your workflow with documented SOPs and layered review, so confirmations, payments, and receipts are handled consistently and partner time stays on the work that needs judgment.

FAQs

Do I use Form 8951 for a brand‑new VCP submission?

Yes. Form 8951 is attached to Form 8950 and carries the user fee for the submission, including the initial general or reduced fee on Line 7 or Line 8. Line 6 is used only when an IRS employee later requests an additional fee on an open case.

How do I pay the Form 8951 user fee?

Form 8951 is filed electronically only on Pay.gov. You submit and pay there rather than mailing a paper check, then save the Pay.gov receipt with your case file.

Which case number goes on Form 8951?

When you add a fee on Line 6, enter the nine-digit VCP case number assigned to your submission. Keep your original Pay.gov receipt and case number together so the payment ties back to the right case.

Can the IRS case close before my payment is confirmed?

The specialist needs confirmation that the user fee was paid to finish processing the case, so save and forward your Pay.gov receipt promptly. Do not send additional fee payments unless the IRS has specifically instructed you to do so.

Are VCP fees still based on participants?

Yes. The general user fee for a 401(a) or 403(b) plan is based on the number of plan participants reported on Line 5, taken from line 6(f) of the most recently filed Form 5500. The amount is no longer printed on the form, so confirm it in the annual Employee Plans revenue procedure 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.