Agreed-Upon Procedures Report on the Pension Benefit Guaranty Corporation Multiemployer Insurance Program (AUP 2017-7/PA-13-94B)

We hired an Independent Public Accountant (IPA) to analyze the three multiemployer plan receiving financial assistance from PBGC. The IPA completed the following procedures:

1. Verified the accuracy of the original benefit computations performed by the plan’s actuary,
2. Verified the benefit payments are being made to eligible participants, and
3. Verified the benefits were properly cutback to the PBGC guaranteed level in accordance with Section 4022A of the Employee Retirement Income Security Act of 1974

The IPA actuaries evaluated forty-eight (48) different test lives across the three plans, and they noted a number of exceptions. Specifically, they noted 15 of 48 exceptions in AUP No. 1, 25 of 48 exceptions in AUP No. 2, and 22 of 48 exceptions in AUP No. 3. These exceptions do not necessarily denote overpayments requiring recoupment, but they do warrant further examination by PBGC.

The OIG recommended corrective action to determine which exceptions require benefit adjustments from plan sponsors, and seek recoupment if necessary.

Personal identifiable information in the report has been redacted.

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