Overview
Title
Proposed Submission of Information Collection for OMB Review; Comment Request; Request for Coverage Determination Form
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ELI5 AI
The Pension Benefit Guaranty Corporation wants to update a form to help figure out which retirement plans it needs to cover, and they're asking people to share their thoughts on this change. They hope to make the form easier to understand and less work to fill out.
Summary AI
The Pension Benefit Guaranty Corporation (PBGC) plans to ask the Office of Management and Budget (OMB) to extend approval for collecting information to determine if a pension plan is covered under title IV of the Employee Retirement Income Security Act of 1974 (ERISA). They are making changes to the Request for Coverage Determination form to improve clarity and remove outdated references. The PBGC invites public comments on the necessity and efficiency of the information collection and aims to reduce the burden on respondents. By May 9, 2025, comments can be submitted through the Federal eRulemaking Portal or by email.
Abstract
The Pension Benefit Guaranty Corporation (PBGC) intends to request that the Office of Management and Budget (OMB) extend approval, with modifications, under the Paperwork Reduction Act, of a collection of information necessary for PBGC to determine whether a plan is covered under title IV of the Employee Retirement Security Income Act of 1974. This notice informs the public of PBGC's intent and solicits public comment on the collection of information, as modified.
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AnalysisAI
The document titled "Proposed Submission of Information Collection for OMB Review; Comment Request; Request for Coverage Determination Form" involves the Pension Benefit Guaranty Corporation (PBGC). PBGC plans to extend and modify the approval for collecting information necessary to determine if a pension plan is covered under title IV of the Employee Retirement Income Security Act of 1974 (ERISA). The PBGC is seeking public comment on these proposed changes by May 9, 2025.
General Summary
PBGC aims to request the Office of Management and Budget (OMB) to continue approving their information collection practices, with updates to improve clarity and remove outdated references in their processes. Specifically, the modifications pertain to the Request for Coverage Determination form, essential for determining whether certain pension plans fall under PBGC insurance. The document details submission methods for public comments, emphasizing electronic submissions, and outlines the ways in which the public can contribute their opinions on the proposed collection modifications.
Significant Issues and Concerns
The document notes that a pilot program related to coverage determination expired in 2022 but lacks clarity on how its removal affects the process. Moreover, there is no information on the consequences if the OMB does not extend approval, potentially leaving readers uncertain about future procedures.
Additionally, the document's use of technical terms and references to specific ERISA sections may make it challenging for lay readers to grasp. This could be mitigated by offering more explanations or definitions of these terms. Furthermore, the estimated cost burden of $300 might not reflect all potential expenses, such as indirect costs encountered by plan sponsors. Likewise, it is unclear how the estimated annual burden was calculated, raising questions about the accuracy and thoroughness of these figures.
Public Impact
The public at large may be affected by how efficiently PBGC can assess pension plan coverages. Accurate and streamlined processes ensure that stakeholders, including plan sponsors and participants, have clear understandings of coverage, rights, and responsibilities. Public comments may influence revisions that could lead to more effective governmental procedures and ultimately improve public trust in such administrative functions.
Impact on Specific Stakeholders
Plan sponsors and participants at pension plans are among the most directly impacted. The proposed modifications aim to enhance clarity in the coverage determination process, potentially minimizing confusion and administrative hurdles. However, the lack of clear guidance on the removal of the pilot program might create uncertainty for new plans seeking determinations. Furthermore, if the cost estimates do not accurately represent the financial burdens on sponsors, this could potentially increase financial strain, especially for smaller or resource-limited organizations.
In summary, while the document seeks to refine and extend necessary bureaucratic processes, careful attention must be paid to the clarity, accuracy, and comprehensiveness of these proposals to ensure they meet the needs of all stakeholders effectively. Public involvement is crucial, providing an opportunity to influence positive changes in how pension plans are managed and assessed for coverage.
Financial Assessment
The document discusses a financial estimation related to the "Request for Coverage Determination" form managed by the Pension Benefit Guaranty Corporation (PBGC). Here’s a breakdown of the financial aspects:
Cost and Hour Burden Estimates
The document specifies that the average cost burden associated with completing the "Request for Coverage Determination" form is approximately $300 per submission. Furthermore, it estimates the average hour burden to be 1.5 hours per form. These figures suggest a financial consideration for entities filing these requests, indicating both time and monetary commitments required for compliance.
On an annual basis, PBGC predicts that around 295 forms will be submitted. This results in a total estimated annual burden of approximately 442.5 hours and a financial burden totaling $88,500. These estimates aim to quantify the overall resource expenditure for all participating entities over a year.
Relation to Identified Issues
The financial allocations mentioned invoke certain issues raised in the document. Firstly, while the document provides an estimated cost burden of $300 per submission, this figure may not sufficiently account for all potential costs. Potential indirect costs, such as time spent by plan sponsors in gathering information and consulting with legal experts, might not be fully captured by this amount.
Additionally, the document does not clarify how these cost and hour estimations were derived, leaving room for questions about the assumptions underpinning these calculations. A lack of clarity on whether broader economic or operational factors were considered in these estimates could impact the transparency and accuracy perceived by stakeholders.
Lastly, while minor housekeeping changes to the form and instructions are mentioned, the document lacks detail on how these modifications could potentially influence these financial burdens or create efficiencies. For instance, improvements intended to streamline the submission process could potentially reduce the time and cost for plan sponsors, but such details remain unspecified, leaving stakeholders unsure of ultimate financial impacts.
In summary, the financial aspects referenced in the document illustrate a significant annual commitment by entities involved with the PBGC’s request for coverage determinations. Although the document conveys a clear quantitative estimate, it lacks deeper insight into its financial assumptions and broader implications of proposed changes on future costs.
Issues
• The document mentions a pilot program that expired on September 30, 2022, but does not clearly explain the implications of its removal on the current process for coverage determination.
• There is no explanation of what changes will be made if the OMB does not extend approval for this information collection, potentially leaving readers uncertain about future procedures.
• The use of technical terms and specific sections of ERISA without explanation might make the document difficult for lay readers to understand, such as references to ERISA sections 4021(a), 4021(b)(3), 4021(b)(9), 4021(b)(13), and section 1022(i)(1).
• The average cost burden estimate of $300 may not adequately account for all potential costs associated with the process, such as indirect costs incurred by plan sponsors.
• It is not clear how the estimated total annual burden was calculated or justified, especially in terms of the assumptions made for the average hour burden and cost burden.
• The document could provide more information on the potential impacts or benefits of the proposed modifications to the form and instructions, such as detailing how these changes will improve the determination process.