8955-SSA and 'gap year' for RMD

[AlbanyConsultant]

Participants who were terminated but receiving RMDs didn't need to be reported on the 8955-SSA because they were receiving at least some portion of their benefits.  With 2020 and the RMD waiver, many RMD-eligible participants did not take their RMD.  So when we're working on the reporting this year, they need to be reported on the 8955-SSA for 2020 because the "payment of the deferred vested retirement benefit cease[d] before ALL of the participant's vested benefit is paid to the participant..." (from the 8955-SSA instructions).

I'm wondering if there was something covering this specific situation out there.  Otherwise, there are going to be a bunch of additional people reported... and we know how well the SSA maintains this list, even when the Code D is properly reported at the time of payout. *cough* not overly well *cough*  I certainly don't want to make the decision for my clients and not report people and run the risk of incurring the $10/person/day penalty, and it's not like it's a particularly large amount of work for the typical-size clients we service, but I just figured I'd check the hive-mind since I didn't see anything addressing it myself.

Yes, I know that if the participant has taken their 2021 RMD by the time of the 8955-SSA filing, that would put them back in "pay" status and make them not need the form... but sometimes, getting that information is harder than just completing the form!

Thanks.

[Belgarath]

Wow, good question. I haven't seen anything from the IRS on this either.

[BG5150]

I wouldn't worry about not reporting them this year.

Has anyone been in trouble for missing ANYBODY on an SSA, let alone  someone who missed their RMD payment?

[AlbanyConsultant]

I've never had an issue with missing someone on an SSA before, but watch this be the year someone at the IRS figures out they need to check this.  I mean, what's one last slap in the face 2020 can heap on us? LOL

[Bird]

3 hours ago, AlbanyConsultant said:

So when we're working on the reporting this year, they need to be reported on the 8955-SSA for 2020 because the "payment of the deferred vested retirement benefit cease[d] before ALL of the participant's vested benefit is paid to the participant..." (from the 8955-SSA instructions).

I'd say it didn't "cease" it was "suspended."  

[AlbanyConsultant]

21 minutes ago, Bird said:

I'd say it didn't "cease" it was "suspended."  

So therefore, because the RMD is expected to resume, it is not ceased and no 8955-SSA would need to be filed.  I like that take.