to amend or not to amend for disability determination

With the upcoming 4/1/18 effective date of new disability claims procedures as related to plans which do not use an unrelated party to determine disability, I'm curious if there is a general push to amend these plans so that disability is determined by an unrelated party such as the Social SEcurity Administration or any licensed physician, or just leave as is and deal with the new, potentially more administratively challenging requirements.

We've mainly seen plan sponsors choosing to adopt the new claims procedure rather than amend the disability definition. As a TPA, we are not recommending one course of action over another, but deferring to their advisors. Having the SSA make the determination has its own disadvantages.

We're seeing this issue, too. Query: If a defined contribution plan has a favorable (to participant) definition of disability and amends to a less favorable (to participant) definition, is that a 411(d)(6) cutback? I have done some research and not found anything definitive. dv13, what do you see as the disadvantages of having SSA make the determination? 

21 hours ago, SadieJane said:

, what do you see as the disadvantages of having SSA make the determination? 

 

They typically take months or years to make the determination.