We recently changed administrators mid-year and were told by the new a

[Guest mia]

We recently changed administrators mid -year and were told by the new administrator that they were not responsible for completing the 1099's or 945 for the distributions that were done prior to them taking over. The response was to go back to the old Administrator to have that done. Is that the norm?

[Medusa]

I'm not sure there is a "norm"; it is more a matter of firm policy and funding arrangement. For example, if I am a bundled provider taking over from another bundled provider or an independent TPA, I am not going to prepare forms for distributions they processed. Why? Because I can only issue 1099R's and 945's for my paying agent.

If there are no bundled providers involved, policy varies as to who should report. Often, getting information from the old TPA is problematic. As a general rule, I tell the employer that I will do the 1099's based on the employer providing a complete schedule to me. I simply don't want to assume reporting liability when I must depend on other parties for the information. Also, in the letter where the old TPA is being notified of their termination, we always have the employer include a statement that the old TPA is being held responsible for such reporting, unless a complete schedule (and here we detail what is needed) is provided to the new TPA.