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This is what DOL told me as well, for the 2015 filing. I may try "kicking it upstairs" when I call back again. When you call back again, take the position that any changes made to EFAST that prevent recognition of changed plan names were made in error and should be undone. The DOL cannot legitimately assert that you need to treat the plan after the name change as a separate plan for filing purposes with a new plan number. Respectfully insist that they facilitate changing the name on EFAST as before.

Based upon my experiences with the DOL I support the opinion of rcline46. The DOL folks are comically undertrained, uninformed etc. but with potentially frightening power.

If there is evidence - and that can include credible testimony from witnesses in a position to know - that there is was an established protocol in place for informing new employees or employees in general about how to make elections and change elections and there is no evidence of the employee attempting to make an election, then it's the employee's unsubstantiated claim vs. that evidence. I would see no material risk of disqualification in that scenario, and an equally low risk that the employee would prevail in court on some type of damages claim.