On Monday, April 26, 2021, PBGC will launch a new version of the My Plan Administration Account (My PAA) premium filing application. The most notable changes relate to premium filings created with private-sector software, especially with respect to the “upload” process.
Some practitioners use private sector software that is compatible with My PAA to create and submit premium filings. With this approach, the premium data is stored in an electronic file in “XML” format (created by the private sector software) that meets PBGC specifications.
There are two ways to submit an XML file to PBGC:
- Upload – You can upload the filing directly to PBGC via My PAA.
- Import – You can import an XML file into My PAA’s data entry and editing screens. From there, the review/submission process is the same as if the data had been entered directly into the My PAA editing screens.
With the current version of My PAA, the main advantage of the “import” approach over the “upload” approach relates to error checking. When you import an XML file:
- My PAA reviews the data and notifies you of identifiable errors, inconsistencies or omissions before the filing can be submitted, just as is the case with “screen-prepared” filings.
- With respect to serious errors, My PAA stops the filing from being submitted until the error is corrected. To correct an error, the user edits the data on the applicable screen and proceeds accordingly.
With uploaded filings, however, most of the error checking currently happens after the filing is submitted. If errors or inconsistencies are detected, a letter is sent to the plan administrator, and the only way to fix something to amend the filing, which can result in late payment charges.
We are pleased to announce that with the new version of My PAA, the same pre-submission error checking will be done to XML files regardless of whether they’re imported or uploaded as explained below:
- Pre-submission error checking (i.e., “validations”) – As noted above, uploaded filings will be screened for the same errors, inconsistencies, and omissions as screen-prepared filings prior to submission. Should the screening process uncover any issues:
- You will simply make the necessary changes using your private-sector software and upload a revised XML file.
- Alternatively, you may import the XML file and make the changes directly on the My PAA screens. See "Imported Filings" below for more information on this approach.
- Uploading and submitting no longer occur simultaneously – Because of the new error checking process, once you upload a filing, it will be stored in My PAA as a draft (i.e., “in-process”) until you are ready to submit it. This two-step process has several benefits:
- By making necessary corrections before the filing is submitted, you significantly reduce the likelihood of late payment charges resulting from a mistake in the premium calculation.
- You will be able to correct errors before sending the filing data to the plan administrator to be manually certified.
- If the plan prefers to pay its premium by check, you will be able to print the pre-populated payment voucher as soon as the filing is uploaded. So, if there are no errors to correct, you can send the hard copy for submission and the voucher to the plan administrator in one package or email.
- Upload History Log Available – Every uploaded filing, whether or not submitted, will be stored in the Plan’s My PAA account with a label to indicate the status of the filing, so you can reference them as needed.
- New My PAA “Role” – In the current version of My PAA, anyone with a My PAA account can upload a plan’s premium filings. With the new version, only someone assigned the new role of “Upload Preparer” for a particular plan will be able to upload a filing for that plan and that plan must be included in the Upload Preparer’s My PAA account.
If you uploaded a plan’s filing last year, that plan will automatically be added to your account and you will automatically be assigned the role of Upload Preparer for that plan.
Note that multiple people may be assigned the role of Upload Preparer for the same plan.
- Ability to print “form” at various stages – Once an XML file has been uploaded, any member of the plan’s My PAA team will be able to generate a hard-copy or pdf version of the premium data displayed in “form” format (i.e., in the same format as the illustrative form included in the comprehensive premium filing instructions). This will enable users to wait until after the error checking is complete (and any errors corrected) before sending the form to the plan administrator for manual certification.
- Ability to print voucher before final certification submission – For plans that still prefer to pay their premium by paper check, this feature will enable the “upload preparer” to send the plan administrator the payment voucher (with the My PAA confirmation number on it) and the form to be manually certified at the same time. Then, once the upload preparer receives confirmation that the plan administrator has manually certified the filings, all that’s left to do is log into My PAA and click the “certify” button to officially submit the filing.
- Imported filings – Although the new version of My PAA will continue to facilitate “imports”, the process for doing so will be a little different. For example:
- To import an XML file into My PAA’s data entry and editing screens, you will start by uploading the file using the same process you would use if you were planning to submit the XML directly via the typical upload process. (i.e., without navigating through the My PAA data entry screens).
- After that, the process will mirror the new upload process up to and including the pre-submission error checking steps.
- Once the error checking is complete, you will have the option to import the XML into the My PAA data entry screens, and if errors were discovered, edit the data as needed directly from the My PAA data entry screens, just as if you had entered the data directly into the screen in the first place.
- If you choose to import the XML file, you will automatically be directed to the Filing Details page for that specific filing. From there, the process will be the same as before (i.e., as if you had created the filing by entering the data directly into the My PAA screens.
- New role assigned for prior importers – Given the enhancements to the upload process, we expect many practitioners who have traditionally “imported” XML files created from private-sector software will start using the “upload” approach for the entire filing.
To simplify this transition, we will automatically assign you the role of “Upload Preparer” for any plan that you imported filing last year.
- Filings due in May - As explained in our Overview of Upcoming Changes:
- The migration begins at 5:00 p.m. on Thursday, April 22, 2021, and
- Although your current My PAA roles and plans and all submitted filings for years after 2013 will be migrated to the new system, filings in draft (“in-process”) status at that time will not be migrated.
In early April, we will be posting a video that demonstrates how the new and improved upload process will work, in addition to navigating the rest of the site.
Because the interplay between My PAA and filings created using private sector software is changing, we recommend setting aside a little time to watch the video and to familiarize yourself with the new version of My PAA before you need to submit a filing.