QACA plan with a per pay period match of 100% of the first 1% and 50% of the next 5% of pay. Someone miscalculates and deposits too much match for a handful of participants (including 1 HCE). Most of the match percentages are insignificant (3.63% or 3.72%) of annual comp., but a few are in the 5-10% range for the year.

I would expect to correct the excess because it is caused by a failure to follow the terms of the document. I'm being told that because the plan does not provide for a true up, no correction is made when the deposits exceed the expected percentage either.

Thoughts?

Mistakes get corrected one way or another, usually the sooner the better but not always. True up is not a correction procedure. Existence or absence of true-up provisions does not speak to a mistaken excess contribution.

I've been looking for the answer to this question for a long time. I think what I found is that the excess funds would need to be considered as discretionary contributions and tested, as such. Another correction option that I found that may be allowable is to calculate gains/losses and remove the total from the account as a "forfeiture" of sorts. For what it's worth, we implemented neither of these changes and took the approach of "Let's help them/hope they fix it going forward."