Enrolled Retirement Plan Agent (ERPA) Program Changes
Effective February 12, 2016, the Internal Revenue Service will no longer be offering the ERPA Special Enrollment Examination (ERPA SEE) to become an ERPA. Any current ERPAs will continue to hold the ERPA designation, allowing them to practice before the IRS. Anyone who has passed both parts of the SEE can still become an ERPA if they file the Form 23-EP, Application for Enrollment to Practice before the Internal Revenue Service as an Enrolled Retirement Plan Agent (ERPA). The application for enrollment must be filed within one year of passing both parts of the test.
Final testing window
The final ERPA SEE testing window will begin January 5 and run through February 12, 2016. Candidates may take each part of the test only one time during the January 5 – February 12, 2016, testing window. This testing window will be the last opportunity for employee benefits professionals to become an ERPA. Candidates who have passed only one part of the exam by February 12, 2016, will not have any further opportunities to take the exam. Candidates can register for the test now by going to www.erpaexam.org. Registration closes on January 4, 2016. The registration form can be found at www.erpaexam.org.
Renewal for current ERPAs
The program remains unchanged for current ERPAs. The renewal period for ERPAs will remain as defined in Circular 230, section 10.6. Continuing Education (CE) is still required under Circular 230 and the requisite number of hours of CE must be obtained from an IRS approved CE Provider. A list of IRS-approved providers can be found under the Tax Pros tab.
1. Why did the Internal Revenue Service decide to discontinue offering the ERPA-Special Enrollment Examination (ERPA-SEE)?
Due to a steady decline in the volume of ERPA-SEE test takers, the cost to administer the examination no longer warrants us offering the test.
2. When will the Internal Revenue Service stop offering the ERPA-SEE?
Test candidates still have an opportunity to take the examination from January 5, through February 12, 2016. After February 12, 2016, the test will no longer be offered. Candidates may take each part of the test only one time during the January 5 – February 12, 2016, testing window.
3. If I have passed only one part of the test by February 12, 2016 will there be another opportunity to pass the remaining part?
No. The final opportunity to pass either part of the test is during the January 5, 2016 to February 12, 2016 testing window.
4. How and when can I register for the ERPA-SEE?
Information on registering can be found at www.erpaexam.org. Registration is open now and closes on January 4, 2016.
5. Will this change have any impact on those that currently hold the ERPA designation?
There is no impact to those that are currently ERPAs. After the ERPA-SEE is no longer offered, those with the ERPA designation will continue to have the same rights to practice before the Service, be subject to Circular 230 requirements regarding continuing education and renewal of enrollment, and be able to hold themselves out as ERPAs.
6. Will those who have passed both parts of the ERPA-SEE, but have not yet applied for enrollment, still be able to submit an application for enrollment?
Yes. Form 23-EP, Application for Enrollment to Practice before the Internal Revenue Service as an Enrolled Retirement Plan Agent (ERPA), must be filed within one year after passing both parts of the ERPA-SEE and the candidate must pass a tax compliance check.
7. With the ERPA-SEE no longer offered after February 12, 2016, will there be any changes with respect to continuing education or renewal of enrollment?
No, there are no changes to continuing education or renewal of enrollment requirements for existing ERPAs. Information regarding continuing education and renewal of enrollment can be found under the Tax Pros tab.
8. I am a former IRS Employee Plans agent. Will I still be able to apply to become an ERPA after ERPA-SEE testing ends on February 12, 2016?
No. Former IRS Employee Plan Agents will not be eligible to apply for enrollment as an ERPA after February 12, 2016. Former Employee Plan Agents may apply for enrollment as an enrolled agent based on their technical experience. The IRS may limit their enrollment to employee plan matters. Information about applying to become an enrolled agent can be found under the Tax Pros tab.
9. If I am an ERPA what is the benefit of maintaining this designation after February 12, 2016?
ERPAs can represent their clients before the IRS with respect to issues involving the following programs: Employee Plans Determination Letter program; Employee Plans Compliance Resolution System; and Employee Plans Master and Prototype and Volume Submitter program. In addition, ERPAs are generally permitted to represent taxpayers with respect to IRS forms under the 5500 series and can practice before Appeals, Collection, Counsel and other IRS offices with respect to the above listed matters.
10. If I am not yet an ERPA why should I consider taking the ERPA-SEE before February 12, 2016?
Those holding the ERPA-SEE designation have the ability to practice before the Service with respect to all the programs listed in Q&A 9. Taking and passing both parts of the ERPA-SEE by February 12, 2016, is the last opportunity for pension professionals to obtain the ERPA designation. Only ERPAs, attorneys, CPAs, enrolled agents have the authority to practice in all of those areas. After February 12, 2016, employee benefit professionals who are not ERPAs should consider taking the special enrollment examination to become an enrolled agent, in order to have the authority to practice in those areas mentioned in Q&A 9.