According to the Internal Revenue Service (IRS) July 2010 Special Edition of Employee Plans News, plan administrators of defined benefit and defined contribution plans will not be required to file Form 8955-SSA for the 2009 plan year until the IRS issues further guidance. The form reports plan participants who separate from service with a right to a deferred vested benefit. It replaces Schedule SSA, Annual Registration Statement for Deferred Vested Participants, from the Form 5500 annual return/report. The Social Security Administration (SSA) uses the data to alert retirees filing for Social Security benefits of any benefits available to them under an employer plan.
The IRS has not yet published the new Form 8955-SSA. The information reported on the new form will be similar, if not identical, to the information previously required for Schedule SSA, so plan sponsors should continue their existing data collection procedures. The data include Social Security numbers and deferred vested benefit amounts of separated participants who are still due benefits at the time of filing. Plans will need to update the data as necessary to delete any deferred vested participants who are cashed out before filing.
Deferred vested single-employer plan participants are generally reported in the plan year following the plan year of the separation from service. Earlier reporting is permitted, but participants should not be reported more than once except to update or revise a filing. Multiple employer plans must report participants who (1) incur two consecutive one-year breaks in service (as defined in the plan for vesting purposes), and (2) are (or might be) entitled to a deferred vested benefit before the SSA report due date.
At this time, the IRS does not have the statutory authority to require Form 8955-SSA to be filed electronically. If electronic filing becomes available, it will be optional. Plans will submit the new forms to the IRS Service Center in Ogden, Utah (the same location that processes Form 5558, Application for Extension of Time to File Certain Employee Plan Returns).