Overview
Premium filings that are uploaded — like filings prepared within My PAA — must be certified. The plan administrator must certify all the information in the filing, and for many single-employer plan filings, an enrolled actuary must certify the variable–rate premium (VRP) information in the filing. In addition, in some cases, the person doing the upload (i.e., the “upload preparer”) must certify that certain required procedures have been followed.
The upload certification procedures are designed to ensure that the plan administrator and enrolled actuary know what information they are certifying, and that the information uploaded has been certified, while making the process as simple as possible.
Premium filings that are uploaded — like filings prepared within My PAA — must be certified. The plan administrator must certify all the information in the filing, and for many single-employer plan filings, an enrolled actuary must certify the variable–rate premium (VRP) information in the filing. In addition, in some cases, the person doing the upload (i.e., the “upload preparer”) must certify that certain required procedures have been followed.
The upload certification procedures are designed to ensure that the plan administrator and enrolled actuary know what information they are certifying, and that the information uploaded has been certified, while making the process as simple as possible.
Details
Where are the certifications made?
Depending on the situation, the certification for an uploaded filing is either made electronically on a screen that My PAA will present to you as part of the upload process or manually on a paper copy of the information to be certified.
Who certifies what?
- Plan administrator certification - The plan administrator must certify all of the information included in an uploaded filing.
- Enrolled actuary certification - If the enrolled actuary certification is required, the enrolled actuary must certify the variable-rate premium information contained in an uploaded filing. See the comprehensive premium filing instructions for information about when the enrolled actuary certification is required.
- Uploader certification - If the person uploading the filing is not the plan administrator, that person (the upload preparer) must certify that:
- He or she is authorized to submit the filing to the PBGC (that authorization need not be in writing),
- The plan administrator has certified the information contained in the filing, and
- If the enrolled actuary certification is required (and the upload preparer is not the enrolled actuary), that the variable-rate premium data contained in the filing has been certified by the person reported in the filing as the enrolled actuary.
In some cases, the same person plays more than one role. For example, the enrolled actuary may also be the upload preparer. In other cases, three separate individuals are involved.
How are the certifications made?
How the certifications are made varies depending on who performs the upload:
- If the person who uploads the filing is the plan administrator, that person provides the plan administrator certification directly on the My PAA upload screen. If the enrolled actuary certification is also required, the enrolled actuary certifies the variable-rate premium (VRP) section of the filing by manually signing a document that shows the data contained in the xml file that will be uploaded.
- If the person who uploads the filing is the enrolled actuary responsible for certifying the VRP section of the filing, that person provides the certification directly on the My PAA upload screen. In this situation, the plan administrator certifies the filing by manually signing a document that shows the data contained in the xml file that will be uploaded.
- Otherwise, the uploader preparer certifies what he or she needs to certify on the My PAA upload screen and the plan administrator certifies the filing by manually signing a document that shows the data contained in the xml file that will be uploaded. If the enrolled actuary certification is also required, the enrolled actuary also certifies the VRP section of the filing manually.
How is manual certification done?
A manual certification must be signed and dated in ink before the filing is uploaded. Most private sector software enables the user to create an illustrative form containing the filing data and the applicable certification language that can be printed or saved as a pdf. Typically, if a manual certification is needed, the uploader sends that illustrative form to the person who is certifying manually. If some other document is used, the certification language must be the same as on the “illustrative form” included with the comprehensive premium filing instructions for the applicable plan year.
Original documents containing the manual signatures of the plan administrator and, if applicable, of the enrolled actuary, are subject to audit and must be retained with plan records for six years from the due date of the filing. After a paper copy of premium information is certified, it may be converted to electronic form for preservation in the plan records subject to the requirements of subpart E of the PBGC's regulation on Filing, Issuance, Computation of Time, and Record Retention (29 CFR Part 4000).
Once an uploaded filing has been submitted to PBGC, it is recommended that the uploader send a copy of the filing receipt to the plan administrator (i.e., a hard copy that shows the submitted data in “form” format) for his or records.
Examples
There are many possible workflow patterns for preparing, uploading, and certifying premium filings. Here are some examples to illustrate the process:
- Example 1 - EA Al, an enrolled actuary, is assigned two roles in Plan X’s My PAA account: Enrolled Actuary and Upload Preparer. EA Al uses private sector software to prepare a filing for Plan X. Once the filing is complete, he emails a pdf version of the filing data (from the private sector software) to PA Pauleen, the plan administrator.
PA Pauleen prints out the pdf, manually signs and dates the hard copy in the space provided for “Plan Administrator Certification” and sends EA Al a copy of the signed document. EA Al then uploads the filing. As part of the upload process, on the My PAA upload screen, EA Al certifies that he is authorized to upload the filing, that the plan administrator has manually certified the filing. In addition, if the enrolled actuary certification is required, EA Al also makes that certification on the My PAA upload screen.
Once EA Al submits the filing to PBGC, he sends a copy of the PBGC filing receipt to PA Pauleen. PA Pauleen then files that receipt along with the certified hard copy of the filing data (i.e., the document containing her manual signature) with plan records.
- Example 2 - TPA Tessa, a third-party administrator, is assigned one role in Plan Y’s My PAA account: Upload Preparer. TPA Tessa prepares a filing for which no VRP certification is required using private sector software. She then mails a hard copy of the filing data (from the private sector software) to PA Paul, the plan administrator.
PA Paul manually signs and dates the hard copy in the space provided for “Plan Administrator Certification” and then sends TPA Tessa a copy of the signed document. TPA Tessa then uploads the filing. As part of the upload process, on the My PAA upload screen, TPA Tessa certifies that she is authorized to upload the filing and that the plan administrator has manually certified the filing.
Once TPA Tessa submits the filing to PBGC, she sends a copy of the PBGC filing receipt to PA Paul. PA Paul then files that receipt along with the certified hard copy of the filing data (i.e., the document containing his manual signature) with plan records.
- Example 3 - TPA Tom, a third-party administrator, is assigned one role in Plan Z’s My PAA account: Upload Preparer. Plan Z’s filing requires an enrolled actuary’s certification.
The enrolled actuary, EA Ed prepares a document containing all the required VRP data for the filing, including the enrolled actuary’s certification language. EA Ed manually signs the enrolled actuary’s certification section of the document and sends the signed copy to TPA Tom.
While preparing the filing using private sector software, TPA Tom enters the certified VRP information provided by EA Ed. Once all the data has been entered, TPA Tom sends a hard copy of the filing data (from the private sector software) to the plan administrator (PA Patty), along with a copy of the information provided by Robert to Elizabeth. Although not required, it is recommended that EA Ed be copied on that correspondence.
PA Patty manually signs and dates the hard copy of the filing data in the space provided for “Plan Administrator Certification” and sends TPA Tom a copy of the signed document. TPA Tom, then uploads the filing. As part of the upload process, on the My PAA upload screen, TPA Tom certifies that he is authorized to upload the filing, that the plan administrator has manually certified the filing, and that the enrolled actuary has manually certified the VRP data included in the filing.
Once TPA Tom submits the filing to PBGC, he sends a copy of the PBGC filing receipt to PA Patty. PA Patty then files that receipt along with the certified hard copy of the filing data (i.e., the document containing her manual signature) with plan records. TPA Tom also sends a copy of the filing receipt to EA Ed for his records.