Online Premium Filing Frequently Asked Questions (PBGC.gov)

A: If you have premium e-filing questions after reviewing the information on this page, please refer to the My PAA Users Manual for detailed step-by-step instructions on how to use My PAA, or to the premium filing instructions for each plan year. Also note that the My PAA screens include instruction links about how to use My PAA and about the data elements that must be entered (for screen and imported filings).

If you still have questions, call 1-800-736-2444 (select the “premium” option) or send an e-mail to premiums@pbgc.gov. (For TTY/TDD users, call the federal relay service at 1-800-877-8339 and ask to be connected to 1-800-736-2444.) PBGC’s business hours are 8:00 a.m. to 5:00 p.m. Eastern Time Monday through Friday, except federal holidays.

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Q: How do I set up/change my account information?

A: To use My PAA, you must first establish an account that will include your user ID and password, your secret question/answer, and at least one plan for which premiums will be e-filed. To set up your account, click on “Sign Up for My PAA – New Users Only” and provide the information requested (e.g., e-mail address).

After you establish your account:

If you will be the filing coordinator for one or more plans, you can add plans to your account from your “Home Page”.
If someone else will be the filing coordinator, that person needs to “invite” you to be part of each plan’s filing team.

Note:

You will use only one account for all of your plans.
Once your account is established, you can make changes (if needed) to your name, telephone number, e-mail address, and password.
You cannot change your user ID, secret question, or secret answer.

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Q: How can I change the plan name or administrator/sponsor address shown in My PAA?

A: The name of each plan is displayed on the Home Page as well as the Plan Page. In addition, each Plan Page displays the sponsor’s name/address and the plan administrator’s name/address. If this information needs to be changed, you can generally do so by including the updated information on the plan’s next premium filing. After the submitted information is reflected within PBGC’s premium processing system, the updated information will be reflected within My PAA. Note that uploaded filings will only result in updates to the Plan Page -- the Plan Name on the Home Page will not be updated.

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Q: What does it mean to be a plan’s filing coordinator or part of the filing team?

A: As in the “paper world,” there may be one person or several people involved with preparing, signing, and paying a premium filing in My PAA for a plan. To make this process run smoothly in My PAA, each plan/sponsor must designate a person (preferably more than one) who will be the filing coordinator for the plan. The filing coordinator is the person who typically oversees the premium filing process, ensures that filings are submitted timely, and performs administrative tasks in My PAA. If a plan is left without a filing coordinator (e.g., the only filing coordinator leaves unexpectedly), you will need to contact PBGC’s representatives for assistance at 1-800-736-2444 (select the premium option) or send an e-mail to premiums@pbgc.gov. Note that PBGC’s business hours are 8:00 a.m. to 5:00 p.m. Eastern Time Monday through Friday (except federal holidays).

The filing coordinator starts the filing process by setting up an account and (if necessary) adding the plan to that account. The filing coordinator then "invites” each person who will be part of the plan’s filing team (if applicable) and sets up what each person can do for each plan (create/edit data, certify as plan administrator, certify as enrolled actuary, select the payment method, view a plan’s account history, or act as filing coordinator). Once an invited person has signed up for an account or if the invited person already has an account, his/her name will be listed as part of the plan’s premium filing team of practitioners on the Plan Page, and on the Filing Manager Page for a filing in process. The filing coordinator can subsequently make changes as needed (e.g., add or remove filing team members or modify permissions).

The e-filing team concept most fully applies to two of the e-filing methods -- using the My PAA data entry and editing screens or importing software-prepared filings into My PAA’s editing screens. For the upload filing method, the filing coordinator needs to verify that the authorized uploader has an account -- with at least one plan in the account (not necessarily a plan for which a filing will be uploaded). If the uploader does not already have a plan in his/her account, the filing coordinator can “invite” the uploader to be part of the plan’s filing team.

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Q: What are My PAA “permissions” and how are they used?

A: As in the “paper world,” electronic filing also has business rules that require certain people to perform certain tasks, e.g., only the plan administrator can use My PAA to sign an electronic filing as the plan administrator. The ability to perform these tasks in My PAA is controlled by the set of “permissions” a person has for a certain plan. The plan’s filing coordinator is responsible for establishing and editing each e-filing team member’s permissions.

Standard My PAA Permissions -- All filing team members can:

Use the My PAA data entry and editing screens to create and edit a filing for each plan in their account.
Import a software-prepared filing for each plan in their account
Upload a software-prepared filing for any plan.

In addition, a plan’s filing coordinator or plan administrator can submit filings that contain all the required information, e-signatures, and authorizations.

Optional Permissions -- The filing coordinator for a plan is responsible for setting the following optional permissions for each person on the plan’s e-filing team (as appropriate):

Sign and submit the filing as the plan administrator
Sign the filing as the enrolled actuary
Select the payment alternative
View the plan’s account history
Perform filing coordinator tasks

Since filing team members can have different permissions and only one person can work on a filing at a time, filings (that were either created with the My PAA data entry and editing screens or imported into the My PAA editing screens) are “routed” to the appropriate team members for action (e.g., for the plan administrator to e-sign). This means that more than one person may be required to complete, sign, and submit filings created in My PAA or imported into My PAA. For the upload filing method, only one person is required to upload filings and that person only needs to have at least one plan in his/her account.

My PAA also has a permission that the filing coordinator can give to any e-filing team member called “View the plan’s account history.” If a person has this permission, he/she can view an online account history from the Plan Page that shows the filings and payments PBGC has received from that plan, regardless of the filing or payment method used to submit them.

Backup Filers are Recommended -- It is strongly recommended that there be one or more back-ups for all e-filing roles/permissions (e.g., plan administrator, enrolled actuary, payer, filing coordinator) to help ensure continuity as people go on vacation or leave the company. (Note that when a plan is initially added to a filing coordinator’s account, there may be a delay before the filing coordinator can add another filing coordinator.) As changes occur to the team of people available to contribute to a plan’s e-filing, the filing coordinator makes changes to the filing team members (e.g., permissions may be changed and practitioners may be added to, or deleted from, the plan’s filing team).

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Q: How are premium e-filings certified/signed?

A: The premium filing certification requirements have not changed with the implementation of electronic filing. The plan administrator must always certify each filing while the enrolled actuary must certify certain types of filings. What electronic filing has changed is how the certifications are completed.

For filings that are prepared via the My PAA data entry screens and for software-prepared filings that are imported into the My PAA screens, all certifications are made on the My PAA screens. This is why each certifier must have an account (e.g., user ID and password) and the plan must be included within each person’s account.

For software-prepared filings that are uploaded into My PAA, the plan administrator or enrolled actuary may certify directly on the My PAA upload screen if he/she is the uploader. If the plan administrator or enrolled actuary is not the uploader, the certification is typically made on a paper copy of the filing information printed from the software. Certified copies of filing information are subject to audit and must be retained with plan records for six years from the due date of the filing (they are not submitted to PBGC).

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Q: Who can submit e-filings to PBGC?

A: For filings created in My PAA’s data entry and editing screens or imported into My PAA’s editing screens, only the filing coordinator or plan administrator can actually submit e-filings to PBGC after the filings are completed and certified (i.e., they are the only people who will be able to see and click the “Submit” button that will send the filing to PBGC’s processing system). In order to submit the e-filing, the submitter (i.e., the filing coordinator or plan administrator) must first be holding the filing. For completed filings that will simply be uploaded to PBGC, anyone who is authorized to upload on behalf of a plan can submit the file to PBGC.

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Q: How do I know a premium filing was received by PBGC?

A: My PAA will always display a confirmation to the submitter that shows the date and time that PBGC received the filing/file. More specifically, for filings created in My PAA or imported into My PAA, the confirmation is e-mailed to the filing coordinator, the people who signed the filing (the plan administrator and enrolled actuary, if applicable), and the person who made the payment method selection. For uploaded filings, the confirmation is only displayed to the uploader of the file and if the uploader chooses, he/she can receive a confirmation e-mail as well.

In addition, the following online information is available:

For filings created in My PAA’s data entry screens and for software-prepared filings that are imported into My PAA, a receipt is available on the Plan Page that shows the date and time of receipt, the confirmation number, and the actual data that was submitted to PBGC. All filing team members can view this information.
For uploaded files, only the uploader can view the following information on his/her Home Page: the date and time the file was received, the My PAA confirmation number, and summary information entered by the uploader, e.g., the file name, comments, and payment selection (if applicable). Note that the submitted filing data for each filing (within the uploaded file) cannot be viewed within My PAA.
All premium filings and payments are eventually posted to a plan’s account history, which reflects a plan’s premium filing history by plan year. The account history can be viewed online from the Plan Page to ensure that a plan’s filings are up-to-date, to verify that the information is accurate, and to determine whether there are any underpayments or overpayment that need to be addressed. Note that there will be a delay between when a filing is submitted and when it shows on the Account History. (See the next question/answer for more information.)

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Q: How can I view a plan’s account history online?

A: To view a plan’s account history in My PAA, a person must have an account (e.g., user ID and password), have the plan in his/her account, and have the “permission” to view the plan’s account history. This can be done regardless of the e-filing method that is used. While each person is responsible for setting up his/her own account, the plan’s filing coordinator must invite you to be part of the plan’s filing team and “permit” you to view the plan’s account history. (See the previous question/answer for more information.)

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Q: How do I report/handle EIN/PN changes?

A: EIN/PN changes should be reported carefully via a premium filing and should not be handled by adding the new EIN/PN to your account.

If the plan that has an EIN/PN change is in your account, do not add the new EIN/PN to your account. Instead, report the EIN/PN change on your next premium filing, which you will create by clicking “Create Filing” next to the plan with the old EIN/PN. The old EIN/PN will populate the “Previous EIN” and “Previous PN” fields and the new EIN/PN should be entered in the “Current EIN” and “Current PN” fields.
If the plan that has an EIN/PN change is not in your account, you will need to add this plan to your account before you can create or import a premium filing for it. When adding the plan, be sure to add it using the old EIN/PN. Report the EIN/PN change via your next premium filing, which you will create by clicking “Create Filing” next to the plan with the old EIN/PN. The old EIN/PN will populate the “Previous EIN” and “Previous PN” fields and the new EIN/PN should be entered in the “Current EIN” and “Current PN” fields.
When you submit filings with EIN/PN changes, My PAA automatically adds the plan with the new EIN/PN to your account. You will see it listed in the “Plans in Your Account” section of your Home Page in addition to the plan with the previous EIN/PN.
The receipt for the filing that shows the EIN/PN change can be found on the Plan Page for the plan with the old EIN/PN.
If an EIN/PN is being changed to the EIN/PN of another existing plan, the change should typically be reported as a merger, consolidation, or spinoff rather than as an EIN/PN change.

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Q: How do I amend a previously-submitted e-filing?

A: Once an e-filing is submitted, that specific e-filing cannot be pulled back or changed. Any changes or corrections must be submitted via an amended e-filing. To amend a filing, you must prepare and submit a fully completed filing with the amended filing block checked. The amended filing will then completely replace the previously-submitted filing.

While an amended filing should be created and submitted to reflect substantive changes (e.g., a change in the participant count), an amended filing is not required for non-substantive changes such as a change in the type of payment that will be submitted outside of My PAA (e.g., if you subsequently decide to send a paper check rather than send an electronic funds transfer to PBGC).

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Q: How do I access/use the Home Page, Plan Page, and Filing Manager Page?

A: If you have a My PAA account, you have a Home Page. If you have a plan in your account, you have a Plan Page. If you have a My PAA screen filing or an imported filing that is in process, you have a Filing Manager Page. See below for details.

Home Page

Every time you log into My PAA, the first page displayed is your Home Page. The Home Page reflects all of the plans that are in your account and serves as your “base of operations” for all My PAA activities. For example:

If you will be the filing coordinator for one or more plans, you can add a plan to your account or invite another practitioner to each plan in your account from your Home Page.
If you have plans in your account, you can create a filing within My PAA or import a software-prepared filing into the My PAA screens.
If you have at least one plan in your account, you can upload a filing for that plan or any plan (even for plans not reflected in your account). Your Home Page also reflects summary information about any files that you uploaded.

Plan Page

Each plan in your account has a Plan Page, which you access by clicking on the “Go to Plan Page” button to the right of the plan’s name in the Plans area of your Home Page. The Plan Page includes the following information:

If a filing is being worked on by another person, you can view (but not edit) the filing in process by clicking on the View/Manage Filing button in the section “Premium Filings in Process Online”.
A plan’s filing coordinator can make changes to a plan’s e-filing team, e.g., to change a person’s permissions (by clicking on his/her name) or to remove a practitioner from the team (by clicking the Remove button).
All filing team members can access the filing receipts for filings submitted that were created via the My PAA screens or imported into the My PAA screens.
The plan’s account history is available online if the person has the permission to view the plan’s account history.

Filing Manager Page

The Filing Manager Page is only available if there is a My PAA screen filing or imported filing in process that has not yet been submitted to PBGC. To access the Filing Manager Page, click the View/Manage Filing button or the View button next to the in-process filing on your Home Page or Plan Page (as follows):

If you are “holding” the filing, the in-process filing will appear in the Inbox section on the Home Page and also in the Premium Filings In Process Online Section on the Plan Page. In addition, the Filing Status section of the Filing Manager Page will say “You are holding this filing”.
If someone else is “holding” the filing, the in-process filing will only appear in the Premium Filings In Process Online section on the Plan Page. In addition, the Filing Status section of the Filing Manager Page will say “You are not holding this filing” and will identify who is holding the filing.

The Filing Manager Page is used by a plan’s e-filing team members to view, complete and submit a filing that was created in the My PAA screens or that was imported into the My PAA screens. Once a filing is created, team members open the filing and take action on it via the Filing Manager Page. Any team member can review the draft filing in read-only mode. However, to take action on a filing (e.g., make edits or sign it), you must have the appropriate permission (e.g., sign as the enrolled actuary) and must be holding the filing (see above information). If someone else is holding the filing, he/she can route it to you (by clicking on the Route To button on the Filing Manager Page) so you can take the necessary action. If you are the Filing Coordinator, you can retrieve a filing in process (by clicking on the Retrieve Filing button on the Filing Manager Page) so you can take the necessary action (e.g., submit the filing).

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Q: How can I help ensure that my premium filing is accurate and complete?

To submit an accurate and complete premium filing, you must report the data in accordance with each plan year’s premium filing instructions. Here are a few filing reminders, primarily from the Comprehensive Filing instructions:

Report Complete Information: Be sure to answer all questions fully and to provide all information requested. For example, dates should include a 4-digit year (e.g., 01/01/2009); and all related questions within an item should be answered (e.g., include all requested dates and explanations).
Submit Appropriate Type of Filing: Large plans (500 or more participants for the prior plan year) should not submit Estimated Flat-rate filings after the Comprehensive/Final Filing due date has passed. (My PAA will not allow this scenario for screen filings and imported filings.)
Alternative Premium Funding Target Election: Once a plan has made the election to use the alternative premium funding target, this election cannot be revoked for any premium payment year that begins less than five calendar years after the beginning of the premium payment year for which the election was made. If an election is in effect, you should not submit a filing that includes an election again.
Premium Funding Target: If a plan is using the standard premium funding target method, the filing must include all three segments for the discount rates. If the plan is using the alternative premium funding target method, the filing must include either all three segment rates OR a selection that the full yield curve was used.
Amended Filing: If you are making changes to a previously-submitted filing, the amended filing box should be checked; and the amended filing questions should be answered fully. A Variable-rate Premium reconciliation filling (in which you provide final Premium Funding Target information after having reported an estimated Premium Funding Target) is also considered to be an amended filing.
Reporting Dollar Amounts: With the exception of total premium, premium credits, the amount due PBGC, and the amount of any overpayment, money amounts should be in dollars only (no cents).
Treatment of Overpayment: If a filing indicates that the plan has an overpayment, the filer must choose whether to have the overpayment refunded (by check or EFT) or credited toward the next year's premium for the plan. If EFT, the filer must provide the banking information requested.

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