The Department of Labor (DOL) has issued guidance regarding missing participants, including a list of best practices to reduce missing participant issues. Such practices include but are not limited to the maintenance of accurate participant census information, searches for missing participants, and implementation of effective participant communications. The DOL also outlined ways that plans should search for missing participants, including but not limited to cross checking plan and employer records, attempting contact via email, telephone or text, and using social media for clues to indicate a participant’s present location.
Additionally, the DOL outlined the general investigative approach for the Terminated Vested Participant Project, undertaken by the Employee Benefits Security Administration (EBSA), which specifically concerns the issue of missing participants. The focus of missing participant investigations centers on plans with a history of issues concerning timely distribution of benefits and terminated vested participant tracking. Investigations include requests for plan documents and participant census records as well as assessments of participant and beneficiary communications practices. Systemic recordkeeping errors and inadequate procedures for contacting participants approaching normal retirement age in particular are on the DOL’s radar.
www.pionline.com; January 13, 2021.