Are 403(b) vendors allowing a participant to self-certify hardship?

[Peter Gulia]

If a nongovernmental and nonchurch charitable organization prefers to make available voluntary-only wage-reduction arrangements to buy a contract with Internal Revenue Code § 403(b) Federal income tax treatment and do so without establishing or maintaining a plan that would be ERISA-governed, such an employer prefers to avoid discretionary decision-making.

That includes avoiding discretion about whether a participant has a hardship withing the meaning of § 403(b)(7)(A)(i)(V) or § 403(b)(11)(B).

Many public-school employers too prefer to avoid involvement in those decisions.

Are 403(b) insurers and custodians allowing a participant to self-certify her hardship?

Does allowing self-certification help remove not only an employer but also an insurer or custodian from discretionary decisions about hardships?

What’s happening in the real world?