Must Plan Administrators have returning employee/Plan Participants "Reaffirm" Designated Beneficiary

[pwitt]

Greetings:

Here is an interesting question: Say a fully-vested DB Plan Participant leaves (either voluntarily or involuntarily) the company providing said DB Plan. After several years, said employee returns to employment with the same company which is still offering the same DB Plan. Does the Plan Administrator need to have the employee/participant  "reaffirm", in writing, the designated beneficiary for said benefit in the event of death of the participant? Thanks to all who reply in advance!

[pwitt]

And since I said "said" so many times in my post; that's all I've got to say! 🐵

[david rigby]

The title asks "must?"  No, of course not.  However, the employer's procedures for rehires probably do not differ from its procedures for new hires, so Yes.  But more to the point, it would be enormously foolish to assume nothing has changed in this person's personal life "after several years".

[Paul I]

Keep in mind that plan documents have default beneficiary provisions and the Plan Administrator cannot force a participant to make an affirmative elective.  Also keep in mind that a terminated participant who has an accrued benefit can change their beneficiary designation while they remain terminated.

It is good practice to encourage participants to make affirmative elections, and to periodically remind participants to review their affirmative elections.  Some plans have generic communications that center around how life events - including rehire - that can impact benefits and those communications include the reminder to update beneficiaries.

[acm_acm]

14 hours ago, david rigby said:

The title asks "must?"  No, of course not.  However, the employer's procedures for rehires probably do not differ from its procedures for new hires, so Yes.  But more to the point, it would be enormously foolish to assume nothing has changed in this person's personal life "after several years".

Wrapping all of this into one thought is to just do it and be done. The time spent thinking about it will be (or already has been?) more than the time spent just handing them the form.

Done and done.