Online Premium Filing with My PAA FAQs
A: On the top of your Home Page is a link to How to Use My PAA for a brief description of the overall e-filing process. If you have additional questions, 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 within the body of the screens about how to use My PAA and about the data elements that must be entered (for screen and imported filings). In addition, each screen includes links at the top of the screen (e.g., to the My PAA Users Manual) and links at the bottom of the screen (e.g., to the Online Premium Filing with My PAA website page and to the Contact Us information).
If you still have questions, call 1-800-736-2444 (select the "premium" option) or send an e-mail to firstname.lastname@example.org. (For TTY/ASCII 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.
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.
- You will use only one account for all of your plans.
- The primary password requirements include:
- Single Quote ' or Double Quote "
- Equal to = or Percent %
- Asterisk * or Backslash \
- Plus + or Ampersand &
- Greater than > or Less than <
- Semicolon ; or Question Mark ?
o It must be between 10 and 24 characters and contain at least 1 uppercase character, 1 lowercase character, 1 number and 1 special character.
o Do not include spaces or the following special characters:
o Change your password often but not more than once per day.
o Your password is case sensitive so be sure to enter it exactly as you originally set it up.
- Once your account is established, you can make changes to your name, telephone number, e-mail address, and password. To make a change, click the "My Account" link at the top of any page within My PAA.
- You cannot change your user ID, secret question, or secret answer.
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.
A: As in the "paper world," there may be one person or several people involved with preparing, signing, and paying a plan's premium filing in My PAA. To make this process run smoothly in My PAA, each plan/sponsor designates a person (preferably more than one) who will be the filing coordinator for the plan. The filing coordinator is the person who oversees the premium filing process, ensures that filings are submitted timely, and performs administrative tasks in My PAA.
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 verifies 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.
The filing coordinator starts the filing process by setting up an account and adding the plan to that account (if necessary). 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). For My PAA screen-prepared filings and imported filings, the filing coordinator can also retrieve or delete an in-process filing as well as submit a fully-completed filing to PBGC.
A: To become a plan's filing coordinator, you must have an account (e.g., user ID & password) and have the plan added to your account along with the filing coordinator permission. When this is done, the plan will show on your Home page (in the Plans in Your Account section) and your name and permissions will be reflected on the Plan Page (in the Premium Filing Practitioners section). How the plan is added to your account (so that it shows on your Home Page) primarily depends upon whether the plan has a filing coordinator.
- If there is currently a filing coordinator, that person invites you to be part of the plan's filing team and sets your permissions to include being the filing coordinator.
- If there has never been a filing coordinator, the new filing coordinator selects the "Add a Plan as Filing Coordinator" button on his/her Home Page and provides the requested information.
- If a filing team has been left without a filing coordinator, a person outside the filing team (i.e., other than a current team member) selects the "Add a Plan as Filing Coordinator" button on his/her Home Page and provides the requested information.
- For all other situations (e.g., if the listed filing coordinator is no longer available and another team member wants to become the filing coordinator), call 1-800-736-2444 (select the premium option) or send an e-mail to email@example.com. PBGC's business hours are 8:00 a.m. to 5:00 p.m. Eastern Time Monday through Friday, except federal holidays.
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, only a plan's filing coordinator or plan administrator can submit My PAA screen-prepared and imported filings that contain all the required information, e-signatures, and authorizations (the submitter must be holding the filing).
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).
A: There are two ways to access an in-process filing (that was created in the My PAA screens or imported into the editing screens) - from your Home Page Inbox and from the Plan Page:
- If the filing is in the Inbox of your Home Page, it means that you are holding the filing and that you are the only one who can take any action on it at that time. To view or take action on the filing, select the View/Manage Filing button displayed to the right of the filing. This will take you to the Filing Manager Page for that filing. From that page, you can select to view, edit, route, sign, pay or submit the filing depending on your permissions.
- If the filing is not reflected in your Inbox, it means that someone else is holding the filing and only that person can take any action on it (e.g., edit, route, sign). You can, however, still view the filing and see the filing status (e.g., who is holding the filing) by going to the Filing Manager Page via the Plan Page. To do so:
- Select the plan's Go to Plan Page button in the Plans in Your Account section of your Home Page.
- Select the View Filing button next to the filing in the Premium Filings in Process section of the Plan Page.
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 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 (user ID and password) and the plan must be included within each person's account. To certify a filing, a person with the appropriate permission must hold the filing (it must show in your Inbox), select the View/Manage Filing button (next to the filing), and go the Filing Manager Page to see the relevant Sign buttons.
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). For details about the certification requirements, refer to the My PAA Detailed Users Manual.
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 submit e-filings to PBGC. The filing coordinator or plan administrator will see the Submit button(s) on the Filing Manager Page if the following conditions have been met:
- The Filing Status on the Filing Manager Page must show that the filing is ready for submission. This means that the filing is complete, certified, and that a payment method has been selected.
- The Holding Status (in the Filing Status section) on the Filing Manager Page must show that the filing coordinator or plan administrator is holding the filing (which means that the filing will be reflected in that person's Inbox on the Home Page).
For completed filings that will be uploaded to PBGC, anyone who is authorized to upload on behalf of a plan can submit the XML file (containing one or more premium filings) to PBGC by selecting the Submit button that is offered during Step 1 of the upload process.
A: My PAA will display a confirmation to the submitter that shows the date and time that PBGC received the filing/file. In addition, for filings created in My PAA or imported into My PAA, the confirmation is e-mailed to 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). In addition, the uploader can view the data submitted on each filing by selecting the Conf. ID/Receipt link for the uploaded file (if a link is displayed); and then selecting each Filing link that is displayed for most uploaded filings (e.g., for Comprehensive Filings).
- 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.)
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.)
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.
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 new filing with the amended filing block checked. For example, if you use My PAA's data entry screens to prepare a filing, you click the "Create Filing" button to prepare a new filing for the plan. On the first My PAA screen, you check the amended filing box to identify the filing as an amended filing. The amended filing must be fully completed because it will replace the previously-submitted filing.
While an amended filing should be created and submitted to reflect most changes (e.g., a change in the participant count or address), 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).
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.
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 are holding an in-process screen-prepared or imported filing for a plan in your account, the filing will be reflected in your Inbox and you can view and edit the filing (as well as see any PBGC warning or error messages) by clicking on the View/Manage Filing button to go to the Filing Manager Page.
- If you have at least one plan in your account, you can upload one or more filings 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 and shows links to the uploaded filing receipts.
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 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 and can view any warning or error messages that are displayed. However, to make any edits to the data, you must be holding the filing. In addition, to certify or pay the filing, you must have the appropriate permission (e.g., to sign as the enrolled actuary) and must be holding the filing. 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).
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 some filing reminders, primarily from the Comprehensive Filing instructions:
- File and Pay Timely and Properly: A filing includes both the submission of required data and the payment of any required premium and must be made by the due date. To help ensure the correct posting of the payment:
- If you pay outside of My PAA (check or ACH), the payment should be only for one plan and must include the plan’s EIN/PN and PYC.
- If you pay by check, be sure to use the correct mailing address which is displayed on our website – either the U.S. Postal Service address (to a P.O. Box) or the Delivery Service address (e.g., for FedEx or UPS).
- The earlier you file the better. In some instances, this will allow plans to be notified about filing errors in time to correct the filing by the due date.
- Report Complete Information: Be sure to answer all related questions and provide all information requested. For example, dates should include a 4-digit year (e.g., 01/01/2013) and new plans should answer two related questions -- the Plan Size question with "N/A; first year's filing" and the New and Newly Covered Plans question with the plan dates requested. Starting with plan year 2013, all plans must report the plan effective date.
- Prepare Appropriate Type of Filing: Large plans (with 500 or more participants for the prior plan year) should not prepare Estimated Flat-rate Filings after the Comprehensive/Final Filing due date has passed. In addition, large plans should prepare a Comprehensive Filing (rather than an Estimated Flat-rate filing) if the plan's final information is known.
- Alternative Premium Funding Target Election: A plan may elect to use the "alternative premium funding target" by checking the box in the "Alternative Premium Funding Target Election" section of the Comprehensive Filing. In order to be considered valid, the election must be part of a timely filing (i.e., submitted by the variable-rate premium due date), for example, by October 15th for a large or medium calendar year plan. 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, do not make an election again. If you are uncertain about the status of your election (e.g., whether an election is in effect), review the plan’s online account history or send an e-mail to firstname.lastname@example.org with the plan's name, employer identification number (EIN), and plan number (PN). PBGC will reply with the status of your election.
- Alternative Premium Funding Target Revocation: A plan may revoke a prior election to use the Alternative Premium Funding Target if the election has been in effect for at least five years. Revocations must be made properly and timely, and must remain in place for at least five years. The plan will be required to use the Standard Premium Funding Target while the Revocation is in effect.
- UVB Valuation Date: The reported UVB valuation date is typically within the plan year and must be used to determine unfunded vested benefits.
- Premium Funding Target Method: The method selected must be in sync with the Alternative Premium Funding Target Election or Revocation:
- The standard method must be used if an election was not previously made, an election was not made on the current filing, or an election is revoked.
- The alternative method must be used if an election was previously made or made on the current filing.
- Only mid-size and large plans have the option to report the premium funding target as an estimate. In addition, the estimated VRP must be reconciled in a timely manner, e.g., by April 30th following the Premium Payment Year for calendar-year plans (the reconciliation due dates are also the small plan due dates).
- Segment Rates: 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.
- For the standard method, these rates must be the segment rates for the month preceding the month in which the Premium Payment Year begins, as shown on PBGC’s website.
- For the alternative method, use IRS-issued 24-month average segment rates acceptable for the UVB valuation date reported OR check the box to report that the full yield curve was used.
- Amended Filing: If you are making changes to a previously-submitted filing, check the amended filing box and answer fully the amended filing questions. 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. An amended filing should include all valid filing data from the previously-submitted filing (e.g., an election or revocation if appropriate). If an amended filing is submitted by the due date, information may be changed if appropriate (e.g., an election or revocation).
- Reporting Dollar Amounts: Assets and liabilities being reported should be in whole numbers only, no cents. Premium, premium credits, the amount due PBGC, and the amount of any overpayment should be in dollars and cents.
- Treatment of Overpayment: If a filing indicates that the plan has an overpayment, the filer must choose whether to have the overpayment credited toward the next year's premium for the plan or refunded (by EFT or check). If EFT, the filer must provide the banking information requested.
- Consider Filing Method Used: Be aware that only My PAA screen-prepared filings and imported filings have up-front My PAA validations, which help to reduce filing errors prior to submission. If you upload filings instead, the premium validations will not occur until after submission; therefore, be sure to closely review the data prepared in approved vendor software products for accuracy prior to uploading the file.
- Submit the Filing and Print Receipt: Be sure to click the submit button to transfer your filings to PBGC. For My PAA screen-prepared filings and imported filings, all e-filing team members can see a receipt that shows the date and time that PBGC received the filing along with all the filing data submitted (on the Plan Page). For uploaded filings, only the uploader can see the date and time that PBGC received the file as well as the data submitted on most filings (via his/her Home Page). It is also suggested that you review the plan’s Account History to verify the posting of the filing/payment and to verify that the plan year is paid in full.
- File and Pay Timely and Properly: A filing includes both the submission of required data and the payment of any required premium and must be made by the due date. To help ensure the correct posting of the payment: