The IRS announced on June 18, 2011, that all qualified retirement plans and ERISA 403(b) plans must comply with a new IRS filing requirement by January 17th, 2012. In short, plans must file the new IRS Form 8955-SSA to report terminated participants with remaining plan balances. The new Form replaces the Schedule SSA that was eliminated in 2009.
What information must be reported?
The Form requires the filer to report any participant who terminated in a prior year and still has a vested benefit from the plan as of the reporting date. For each participant who must be reported, The Form must include the social security number, name and the vested benefit amount for each participant who must be reported.
Example: The 2010 Form must report participants who terminated in 2009 and still have balances at the time of filing. As an option, the 2010 Form could also include those who terminated in 2010.
In each subsequent year, any previously reported participant who has received a full distribution must be reported again with a code indicating the plan no longer owes them further benefits.
How is the information used?
The information is shared with the Social Security Administration (the “SSA”) who maintains it in a database. When individuals apply for Social Security benefits, SSA queries its database and notifies applicants that they are entitled to benefits from the plan.
Do I have to file if I have no terminated participants with balances in 2009 or 2010?
You do not need to file Form 8955-SSA if you have no terminated participant balances in the applicable filing years.
What is the filing deadline? Can I extend the Form 8955-SSA?
Although it is a completely separate filing from the Form 5500, the deadline to file is the same as the Form 5500 deadline, i.e. seven months after the close of the plan year.
The initial Form 8955-SSA filing for the 2009 and 2010 plan years is due January 17th, 2012. The information for both years can be combined on a single Form rather than filing two different Forms. No extensions will be allowed for the initial filing deadline!
For 2011 filing years, the deadline can be extended by an additional 2 ½ months by filing Form 5558.
How do I file the Form 8955-SSA?
At present, the IRS allows a paper filing. In future years, electronic filing may be required.
As a plan sponsor, who should I call to prepare the Form 8955-SSA?
If Clark, Schaefer, Hackett & Co prepares your Form 5500, we will also prepare your Form 8955-SSA. Please contact your plan administrator in the Qualified Plan Administration and Consulting Group for more information.
For more information contact Kim Flach at [email protected]