Terminated participants with a vested accrued benefit or vested account balance must be reported on the Form 8955-SSA.
There is some debate as to whether participants who were previously reported on a Form 8955-SSA or Form 5500 Schedule SSA but who now have been paid out (and thus are no longer entitled to a future benefit) must be reported again. These individuals may always be optionally reported again. The instructions to the Form 8955-SSA indicate that these participants must be reported, but the statutory language does not require these individuals be reported.
Nova 401(k) Associates believes it is appropriate to try to follow the instructions to the Form 8955-SSA. In some cases, records may not be readily available showing who has been reported in the past. However, Nova 401(k) Associates believes employers and 401(k) TPAs should make a good faith effort to report previously reported individuals who have been paid out. This would be consistent with the instructions for the Form 8955-SSA and would prevent these individuals from receiving a letter from the Social Security Administration at some date in the future.