Pension & Benefits News PBGC provides more information about My PAA changes for private-sector software filings
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Monday, April 19, 2021

PBGC provides more information about My PAA changes for private-sector software filings

By Pension and Benefits Editorial Staff

The Pension Benefit Guaranty Corporation (PBGC) has provided more information concerning how the upcoming new version of My Plan Administration Account (My PAA), which will be launched April 26, 2021, will affect premium filings created using private-sector software. The new version of My PAA will streamline and improve the process by including multiple enhancements to improve customer experience with plan management, premium filing, and payment processing. The PBGC has now posted information about the upcoming private-sector software-related changes.

Uploading enhancements. The PBGC notes that practitioners who use private-sector software that is compatible with My PAA to create and submit premium filings to the PBGC submit those XML filings in one of two ways—by uploading or importing the filings. With the current version of My PAA, the main advantage of the “import” approach over the “upload” approach relates to error checking. If a file is imported, checking errors happens before the filing can be submitted. When a file is uploaded, most of the error checking currently happens after the filing is submitted. If errors or inconsistencies are detected, a letter is sent to the plan administrator, and the only way to fix something is to amend the filing, which can result in late payment charges.

In the new version of My PAA, the same pre-submission error checking will be done to the filings regardless of whether they’re imported or uploaded, according to the PBGC. With this improvement, if errors are discovered during a screening, filers may make the necessary changes using their private-sector software and upload a revised XML file, or filers may import the XML file and make the changes directly on the My PAA screens.

The PBGC notes, however, that with the new error checking process, once a filing is uploaded, it will be stored in My PAA as a draft (i.e., “in-process”) until it is ready for submission. Thus, uploading and submitting will no longer occur simultaneously. The benefits of this new process, according to the PBGC, include the significant reduction of the likelihood of late payment charges resulting from a mistake in a premium calculation, the correction of errors before sending the filing data to the plan administrator to be manually certified, and for those plans that pay its premium by check, the ability to print the pre-populated payment voucher as soon as the filing is uploaded.

Other enhanced upload features include:

  • Upload History Log Available - Every uploaded filing, whether or not submitted, will be stored in the plan’s My PAA account with a label to indicate the status of the filing, so the filing can be referenced as needed.
  • 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” for a particular plan will be able to upload a filing for that plan and that plan must be included in the Upload Preparer’s My PAA account. However, the PBGC explains that if a practitioner uploaded a plan’s filing last year, that plan will automatically be added to that practitioner’s account and he or she will automatically be assigned the role of Upload Preparer for that plan. In addition, note that multiple people may be assigned the role of Upload Preparer for the same plan.
  • 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. This will enable users to wait until after the error checking is complete (and any errors corrected) before sending the form to the plan administrator for manual certification.

Imported filings. The new version of My PAA will continue to facilitate “imports”, but the PBGC states that the process for doing so will be a little different.

  • To import an XML file into My PAA’s data entry and editing screens, filers will start by uploading the file using the same process if they were planning to submit the XML directly via the typical upload process. (i.e., without navigating through the My PAA data entry screens).
  • After that, the process will mirror the new upload process up to and including the pre-submission error checking steps.
  • Once the error checking is complete, filers will have the option to import the XML into the My PAA data entry screens, and if errors were discovered, edit the data as needed directly from the My PAA data entry screens, just as if the data had been entered directly into the screen in the first place.
  • If importing is used, filers will automatically be directed to the Filing Details page for that specific filing. From there, the process will be the same as before.

Given the enhancements to the upload process, the PBGC expect many practitioners who have traditionally “imported” XML files created from private-sector software will start using the “upload” approach for the entire filing. To simplify this transition, the PBGC will automatically assign practitioners the role of “Upload Preparer” for any plan that practitioners imported last year.

Source: PBGC website, What’s New for Employers & Practitioners.

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