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Employee Benefit Plans: Locating Missing Participants

6/25/20 – Jovana Krajewski

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As a business owner or benefits manager, you have countless responsibilities to manage. From the everyday tasks of running your business to making sure you remain compliant with various regulations and policies related to benefits, you can easily find yourself overwhelmed. If one of your retirement plan participants has become unresponsive or cannot be located, the responsibility to track them down falls on you and your company. If you neglect the following precautions and the recipient of those benefits takes action, your company could be on the losing end of a costly legal battle. If you are unsure if you are up-to-date on all benefit payments to your current or previous employees, you need to take the proper action now to ensure that you and your company are safeguarded. Here are five helpful tips for tracking down missing participants.

Confirm the Address

The first step that you need to take is to confirm the most recently listed address by using certified mail. This simple step usually clears up most of the confusion. If the individual does not respond to this initial outreach, a forwarding address is typically provided.

Contact Beneficiaries

If you were unsuccessful in confirming the individual’s address, you can begin reaching out to the individual’s listed beneficiaries. If you are successful in contacting the respective beneficiaries, you will either identify the individual in question or identify the individuals who will receive their closing benefits.

Look For Emergency Contacts

If you are unable to identify or contact the listed beneficiaries, it is time to utilize the individual’s emergency contacts. Participants typically select emergency contacts who are responsive and have up-to-date contact information, which should make these individuals fairly easy to contact.

Dig Through Old Employer Records

After the previous attempts to contact your employee or previous employee have been exhausted, you’ll likely resort to digging through old employer records to see if the individual had any secondary addresses or forwarding addresses on file. If any addresses are listed, send a certified mail to the listed addresses and wait for a response.

Perform an Internet Search

A final method that can be used to identify the missing participant is to conduct an internet search. In the age of social media, it is harder than ever for people to remain invisible on the internet. This search should determine the individual’s status, whether they have relocated, are recently deceased, or experienced another life event that has affected their identity.

Additional Search Steps

If after following the above search steps you still cannot locating the missing participant or beneficiary, it is your fiduciary responsibility to consider whether additional search steps are needed.  Commercial locator services, credit reporting agencies, information brokers, investigation databases and analogous services can all be used, however they typically have a cost associated with their services. 

For any questions related to locating missing participants, or employee benefit plans in general, contact VonLehman’s Employee Benefit Plan experts today at jkrajewski@vlcpa.com or 800.887.0437.