Changes to PBGC Premium Filings Involving Private-Sector Software Coming

The Pension Benefit Guaranty Corporation (PBGC) has outlined impending changes related to premium filings involving software developed in the private sector. The changes will be implemented when the new version of the My Plan Administration Account (My PAA) premium filing application is launched on April 26, 2021. 

Uploads

The most notable changes, the PBGC says, concern uploading. With the current version of My PAA, filings that are imported are checked for errors before submission; however, error checks are done after a filing that has been uploaded has been submitted. To correct an error in a filing that has been made after uploading requires amending the filing—which can result in late payment charges. But with the implementation of the new version of My PAA, error checks will be done before final submission, regardless of whether the filing is imported or uploaded.  

Other enhanced upload features under the new version of My PAA include: 

Uploading and submitting no longer occur simultaneously. Because of the new error checking process, once you upload a filing, it will be stored in My PAA as a draft (i.e., “in-process”) until you are ready to submit it.

Upload History Log Available. Every uploaded filing will be stored in a plan’s My PAA account with a label to indicate the status of the filing.
 
New My PAA “Role.” In the current version of My PAA, anyone with a My PAA account can upload a plan’s premium filings. With the new version, only someone assigned the new role of Upload Preparer will be able to do so, and that plan must be included in the Upload Preparer’s My PAA account.

Ability to print “form” at various stages. Once an XML file has been uploaded, any member of the plan’s My PAA team will be able to generate a hard-copy or pdf version of the premium data displayed in “form” format.
 
Ability to print voucher before final certification submission. The Upload Preparer for plans that still prefer to pay their premium by paper check will be able to send the plan administrator the payment voucher and the form to be manually certified at the same time. After the Upload Preparer receives confirmation that the plan administrator has manually certified the filings, he or she will log into My PAA and click the “certify” button to officially submit the filing.

Importing

Although the new version of My PAA will continue to facilitate filing by importing data, the process for doing so will be a little different. For example:

• To import an XML file into My PAA’s data entry and editing screens, one will start by uploading the file using the same process as if one were planning to submit the XML directly via the typical upload process. 
• After error checking is performed, one may import the XML file into the My PAA data entry screens; if errors were discovered, one will be able to edit the data as needed directly from the My PAA data entry screens, just as if it had been entered directly into the screen in the first place.
• Choosing to import the XML file will automatically directed one to the Filing Details page for that specific filing. 

The PBGC says that with the implementation of the new system, it expects many practitioners who traditionally imported XML files created from private-sector software will start uploading the entire filing instead. It adds that to simplify such a transition, it will automatically assign the role of “Upload Preparer” for any plan for which an imported filing was made last year.

Filings
 
For filings due in May, the PBGC says, migration of data begins at 5:00 p.m. on Thursday, April 22, 2021. And although current My PAA roles and plans and all submitted filings for years after 2013 will be migrated to the new system, filings in draft status at that time will not be migrated.
 
Therefore, the PBGC recommends waiting until April 26 to upload an XML file in order to avoid having to do it again after the new version of My PAA is launched, if one plans to use private-sector software for a filing due in May. An alternative, it says, would be to consider submitting the filing early (before the migration begins).