PBGC Coverage Determinations Could Become Easier With New Form

PBGC Coverage Determinations Could Become Easier With New Form

A new Pension Benefit Guaranty Corporation (PBGC) coverage determination form with instructions could streamline and standardize the task of requesting whether a defined benefit plan is covered by the agency’s plan termination insurance program. Under a one-year pilot program, employers could also use the form to request opinion letters about certain plans not yet established. Comments on the draft form and instructions, now awaiting approval by the Office of Management and Budget (OMB), are due by June 7.

Specific Instructions for Certain Plans

Sponsors currently can submit written requests for coverage determinations for all kinds of plans, but have no form or instructions about how to do so. The new form would give specific instructions and require certain supporting information for the four types of plans most often submitted for coverage determinations:

  • Church plans
  • Substantial owner plans
  • Professional service plans with no more than 25 active participants
  • Puerto Rico-based plans

Plans Not Yet in Existence

PBGC can issue coverage determinations only for plans that already exist. A pilot program would let employers use the new form to request an opinion letter on whether a plan not yet established is likely to be exempt from coverage as a professional service or substantial owner plan.

OMB Approval

Federal agencies must request OMB approval of forms requiring or requesting information from the public. OMB’s review ensures the information collection is necessary and won’t impose unreasonable time and cost burdens. OMB may approve a form for up to three years, but an agency that wants to continue using the form can request an extension.

Brian Kearney
by Brian Kearney

Principal, Mercer’s Law & Policy Group

Margaret Berger
by Margaret Berger

Principal, Mercer’s Law & Policy Group

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