The PBGC Seeks Public Comments on Initiative to Improve Service, External Communications

The PBGC is requesting input from the public regarding their communications procedures. Based on the consistent feedback we have received from you, DP3 believes our members may want to provide input in this area.

This page is intended to provide guidance to those who may want to take this opportunity to improve the PBGC's communications procedures.

Comments may be made by email (OIRA_DOCKET@omb.eop.gov ) or by fax (202- 395-6974).

Comments must be sent by April 4, 2011.

Guidelines:

• This is not the venue to object to your benefit. It is the venue to comment on communications problems.
• Be polite. Any angry tirades will only undermine the credibility of the comments.
• Comments will be more effective if you use your own words. If you need to cut and paste the suggested comments, try to personalize them if you are able to. But sending anything will help.
• We suggest copying your comments and emailing them to your Senators and Representative with or without a cover letter/email. Look up your Senator or Representative for their contact information.
• We want to emphasize that the purpose of these letters is to encourage communication and tactfully demonstrate to any Congressional readers that there are legitimate concerns with the current PBGC process. We at DP3 are at least as frustrated as you may be. But our focus is on proceeding in a manner that will have the best chance of effecting change and improving our benefits. A tactful and factual approach is the best way to do that.

Specifics:

A sample letter containing most of the communication issues that DP3 has encountered is available at this link.

Sample paragraphs derived from that letter are below. We suggest taking the issues you are most concerned with and including them in your comments:
1. The PBGC has not implemented email communications with the participants in plans it administers. Email is the primary means of communications in the world today. It allows for much quicker transaction of business and communications, and therefore is more effective for communicating - since it allows timely two–way communications and clarifications.
2. The PBGC mails final determination letters by regular mail, with no special notation on the envelopes. Since the participant in the plan must appeal any concerns within 45 days of the date of the letter (not the date it was sent), these letters should be sent certified mail. A better, fairer, and cheaper solution would be for the PBGC to do away with the 45 day appeal policy and give the participants the same 2 year period the PBGC allows itself for addressing errors.
3. PBGC public contact personnel are very courteous but they are often not knowledgeable about issues regarding the plan. Additionally, they often provide incorrect information about common issues such as the availability of calculation data and appeals procedures. This problem is exacerbated by the use of subcontractors to administer plans. This could be rectified by having specific qualified PBGC experts handling the participants' questions.
4. The PBGC is very inconsistent in the payment of back pay after benefit recalculations. Some participants are paid within a month. Others are paid several months later. Many are not paid until they call the PBGC asking why they aren't being paid.
5. Participants in a plan should not have to use the Freedom of Information Act to acquire basic plan information from the Trustee of their plan (the PBGC). Information about the plan should not take months to be provided to plan participants.
6. The PBGC should provide a full and understandable explanation of the calculation of a participant's benefit at the time their final benefit determination is completed.