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Posted

Just curious how people handle this, because I've had it multiple times where I client inadvertently doesn't give us a Termination Date on the Plan Census.  So this leads to the participant count being incorrect (for instance, someone terminated in '23 but we weren't notified so they were included in the Active Count).

Do you:

1) File an amended '23 form, to correct it?
2) Just file the correct count for '24 and ignore the '23 issue?
3) Carry the mistake forward for consistency, but have the Year End numbers correct for '24?

Obviously the easy thing is to just amend the '23 form and move forward accurately, but I was just curious how everyone handles this.

Thanks!

Posted

Technically, the form should be amended.  Did the change in the count have an impact on the filing (like triggering the audit requirement)?  If yes, we would amend the filing.  If no, we likely would carry the prior year count forward and use the correct year end numbers (assuming that the client doesn't repeat sending inaccurate information).

Since the issue involved a termination date, don't overlook the individual when filing the Form 8955-SSA for the current.  The SSA form is very lenient about who and when someone is reported.

Posted

I agree, would only amend prior year filing if the correction was material. If it doesn't affect audit requirement or materially change active counts then I'd just correct going forward. So, 70 vs 69 - not material - 4 vs 3 I'd think about amending. My opinion FWIW

Kenneth M. Prell, CEBS, ERPA

Vice President, BPAS Actuarial & Pension Services

kprell@bpas.com

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