Bill participant to answer questions?

[Guest Dave Peckham]

Can a participant's account be charged to answer detailed questions? I have a participant who is not a trustee who is asking very detailed questions that require a lot of time to answer. Is there a way to charge this participant's account for this time? It doesn't really seem appropriate to charge the plan sponsor. What else can I do?

[david rigby]

Are you the TPA?

Does the plan permit such an expense?

Does your service agreement with the plan sponsor describe what you charge for?

Does your service agreement describe what level of interaction you will have (or not have) with participants?

[QDROphile]

Does the summary plan description alert participants that explanations about benefits will be charged? Was the participant advised early in the process that the work would be charged, with an oppotunity to cease or restrict the scope of the inquiry?

[Effen]

DB or DC? I assume DC, but just wanted to make sure.

Since the participant got your number from somewhere, who/what gave you the authority to talk to him and who agreed to pay for the cost of that service?

[Bird]

I think you have to push this back to the plan sponsor - tell the participant that you're not the Plan Administrator and that such questions go to the PA. Then the sponsor/PA can come back to you and then you can at least tell him that it's billable time, and make it his problem. (Sorry, maybe you've already been there/done that.) If the participant is asking consulting-type questions then he can certainly engage you for such services.

Of course you run the risk of wasting more time trying not to answer the questions than just answering them.

[david rigby]

If the participant is asking consulting-type questions then he can certainly engage you for such services.

Is this a conflict of interest?

[TPAMan]

When we have an inquisitive participant on our hands, we will typically ask them to prepare a written request for the information they want and submit it to both the Plan Sponsor and us (the TPA). We can then discuss with the Plan Sponsor how best to handle the answers.

Generally, the participant never makes the written request - too much work I guess.

[Guest Dave Peckham]

Thank you all for your replies. I agree that the best answer is to go to the plan sponsor and explain that any further time spent will be billable to the plan sponsor.