8955-SSA & a rehire

[doombuggy]

I have a fiscal plan that I just took over at my new employer. I discovered that a participant who terminated in the 2012 PY was rehired late in the 2013 PY. This rehire was not reported on the 2013 PY census, and she was subsequently reported on the 2013 8955-SSA because she still had a balance. So now she is an active participant, how do I report her on the 2014 SSA? She was never paid out while terminated.

The instructions for this form indicate that she should NOT be reported under Code D merely because she return to the service of the plan sponsor. So do we just leave it go or report her each year as a "b" with updated data? The summary report I ran out of Relius indicates that she should be a "D," but that is contrary to the instructions....

[david rigby]

Just my opinion: don't remove.

Most important: pick a method and stick to it, and make sure everyone in your office does it the same way.

[Tom Poje]

be careful if you do nothing - let's suppose she quits in 3 years and gets paid out the same year (or even the following year).

someone else might run the data that year and might look at the current year data and say "I don't need to report anything on her because she was never reported as having a balance " and therefore she will never be coded a D to take her off the list.

who would remember that she was reported years ago?