LPHR

There are companies that provide this service (of finding terminated employees). I don't recall any names, but your TPA/Service Provider may have some names handy.

I was thinking about the number of participants. If the plan is subject to audit, even if there are 1,000 participants, Murphy's Law says there is a 99% chance, this person will be part of the auditor's random selection.

If this were truly an Employer error when transferring TPAs, there's no responsibility on the part of the employer to make her whole?

I work at a law firm (not in an HR/Benefits role, though that's my background). We have access to an AI platform tied to Westlaw. I use as a short cut to find the given code/regulation I need and maybe provide a summary, but always go back to the primary source. Also love it to draft emails when I'm too tired to think. Even simple emails where tone matters as much as content.

To clarify, was the participant's account (partial or whole) transferred to an IRA before the alternate payee's interest was segregated? From what I understand (i.e., this isn't legal advice), once a Plan receives a DRO (qualified or not), the account should be flagged so that the AP's interest isn't diverted. Apologies if I misunderstood. Was the move to the IRA part of a small balance transfer after the participant termed?

Not everyone (like my 23 year-old son) or his almost 60 year-old uncle drives. Just felt the need to comment based on the face value of the question. Seems like the company would use documentation for I-9 purposes to verify age eligibility.

Also, consider past practice of processing life claims and planned practice going forward. I would aim for consistency. From working on the Benefits Admin side, I've often heard that it will take longer than it actually does to get the death cert. Unless there are extenuating circumstances with an autopsy causing the delay. I was going to say that I would likely take an autopsy report (even a pending one), but that could raise the issue if there were some exclusion at play (was the accident deemed a death by suicide and was the individual in/past the suicide exclusion window).

I'm the AP on my ex's FERS. I believe since I got re-married after age 55, I'm still eligible for the survivor annuity. That's going off information from the QDRO. However, the gov't won't send me a copy of the Plan until my ex retires (sometime this year). Not sure they can withhold the Plan document, but I got tired of asking. Also, as an AP on a Pension benefit, I wouldn't waive my right to a survivor benefit unless I was paid a lump sum approximation of the cumulative payments (longevity runs in my family).

My ex-husband works for the federal government. I had a QDRO for the TSP (DC Plan) which was paid out when the divorce was final in 2009. There is a QDRO on the Pension plan...he's eligible to retire this year, so there are QDROs based on Gov't plans. To Msme, is there a QDRO in place for his Pension benefit? A subsequent spouse of your husband's should not impact the marital portion that was assigned to you when you got divorced and the QDRO was signed. Of course, every plan is different. That's just my experience, not legal advice.

Ugh. That is a mess. For what it's worth, reinstatement can happen almost immediately. Technically, the process would be to wait for the weekly file feed, but given the errors, the COBRA administrator can email the carrier and request immediate reinstatement. Similarly, I have on scores of occasions emailed the insurance carrier once I can see the person has enrolled for COBRA and asked them to reinstate ASAP. I have also manually re-enrolled a participant once I see that they have made the COBRA payment. The process of the file feeds from entity to entity can take a couple of weeks given the sequencing and processing of file feeds. Hopefully things will move along now, but I feel your pain. Do you know the doctor well (i.e., have you been a patient for a while), maybe you can ask them to hold billing you until you know you're reinstated. L

Sorry for the hassle. Question, when you say that you "opted for COBRA" initially, did you acknowledge to the employer's offer of COBRA (as part of a separation agreement) or did you actively apply/enroll for COBRA? Enrollments can get wonky when part of your severance package covers COBRA payments and when you enroll for COBRA around/near Open Enrollment. It happened to me 2 years ago when my position (as a benefits manager) was eliminated in October. The benefits department and the COBRA TPA messed up both enrollments---when first eligible and for the following year. I'm just wondering in the insurance carrier/TPA ever had your enrollment on record. With the October and November statements, were those amounts your former employer paid? I know I asked a lot of questions, but just troubleshooting based on what I've seen happen when administering COBRA on behalf of the employer. I'm glad you received a timely response from EBSA.