Industrial Relations

CONTRACTOR PENSION MANAGEMENT PLAN INFORMATION (PMP) REQUEST
Contracting officers should request contractors to provide DOE the following information no later
than January 31, 2021 via the iBenefits system.
The Pension Management Plan shall include:
1)

2)

A discussion of the Contractor’s plans for management and administration of each defined
benefit (DB) pension plan for which the Department has a continuing obligation to reimburse
pension contributions consistent with the terms of the applicable Contract;
Contributions for the current year and projected contributions for six years on a plan year
and DOE fiscal year basis on the following bases:
a) The minimum required contribution after reflecting any existing credit, carryover and/or
prefunding balance.
b) The contractor’s preferred alternative funding scenario that may include contributions
in excess of minimum required contribution. The overall goal of the alternative scenario
should be to reduce the financial risk of the plan to the DOE. Specific DOE goals for
the alternative scenario would include:
• Avoiding volatility in future contribution levels to support stable budgeting,
including smoothing the impact of the upcoming expiration of temporary funding
relief;
• Achieving full funding levels sooner to permit the employment of de-risking
investment strategies;
• Reducing the likelihood of future benefit restrictions.
Alternative scenarios should include a narrative description of the rationale for the
scenario.
Additional program office specific instructions:
(i) NNSA contractors should limit their alternative funding scenario to the plan's
Normal Cost.
(ii) EM contractors should propose an alternative funding level scenario between
2021 and 2027 plan years that achieves the best overall health of each plan.
This may be a funding level that will achieve a 100% funded status, or another
funding example that achieves a satisfactory level according to the Plan’s
fiduciaries.
c) The third scenario is no longer required.
d) Contractors are welcome to provide additional information as a supplemental attachment
if this information better represents the contractor’s funding philosophy and/or funding
position of the plan 1.

This includes the option to provide years of projection beyond 2027 in the template if such information is needed
to explain the contractor’s preferred funding strategy or note any identified future financial risks relating to the plan.

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3)

The actuarial methods and assumptions underlying the projections, including a description
of how the interest rates for the projection period were determined and a description of the
mortality table used;
4) Information on any changes or proposed changes to the plan, including any changes made or
expected to be made as the result of nondiscrimination testing;
a) The long term strategy to de-risk the plan; for example, changes to the investment
portfolio such as a glide path for the assets shifting from return-seeking investments to
liability-hedging investments; planned settlements of the liabilities by offering lump sum
windows to terminated vested participants or making annuity purchases or implementing
other risk-transfer strategies; a plan design change that shifts or reduces the plan
sponsor’s risk; or making or accelerating additional contributions to reduce PBGC
premiums, mitigate contribution volatility, enable risk transfer strategies, or trigger
investment portfolio changes; and/or any changes to the de-risking strategy from that
submitted in the 2020 Pension Management Plan;
5) A detailed justification, if any funding request proposes a contribution in excess of the
minimum required contribution (an alternative funding strategy). If departmental element
approval has been obtained prior to the submission of the management plan, attach a copy of
that approval as well.
6) The asset mix and indicate if any changes are being considered.
7) The amount of the total investment fees as a percent of the assets.
8) Indicate if the plan sponsor filed for voluntary correction under EPCRS for this plan since
the last PMP. If yes, when and to correct what defect(s)? Attach the application for correction
and the IRS final response, if received, using one of the supplemental attachment slots
provided on the iBenefits form.
9) Actual PBGC premiums for the most recent year and estimates for the next three years.
10) Copies of the following documents to the iBenefits form:
a) the actuarial valuation report for the most recent plan year if not provided during the first
quarter data call for FY 2021
b) the 2020 plan year PBGC premium form and 4010 filing (if applicable);
c) copies of plan documents, plan amendments, investment policies and IRS determination
letters if there have been any changes since the last PMP was submitted;
d) copies of any asset liability studies or experience studies if any have been performed
since the last PMP.
11) Benefit Restrictions and Endangered Status
a) If the plan is a single employer plan subject to ERISA funding requirements and the
plan’s Funding Target Attainment Percentage is estimated to be less than 85% for the
2021 plan year, provide information regarding benefit restrictions including the benefits
that could be affected and the estimated number of people that might be affected.
b) If the plan is a multiemployer plan and the ratio of the actuarial value of the assets to the
present value of accrued benefits is estimated to be less than 85% for the 2021 plan year,
provide an explanation regarding the potential impact to the plan’s future funding
requirements in the event the plan enters endangered status.
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12)

13)

14)

15)

c) If the plan is a multiemployer plan, please provide estimate of what status the plan is
expected to be for the 2021 plan, critical, endangered, no
Any modelling or other analysis performed to assess the potential impacts to the plan of asset
return or interest rate shocks. Include any analysis performed to assess the impact of recent
market corrections.
If the plan is not required to perform nondiscrimination testing, for example; it is a public
plan, the plan only covers bargaining unit employees, no highly compensated employees
(HCEs) participate in the plan, or the plan has been amended to freeze benefits for HCEs;
state the reason the plan is not required to test and skip items (14) and (15). If the benefits
for HCEs were frozen, provide the effective date of the freeze.
Identify any issues that have recently occurred or that may be projected to occur in the next
18 months that could cause the plan to be deemed non-qualified to include failing coverage,
nondiscrimination requirements, etc. Describe any preliminary nondiscrimination testing
that has been conducted with respect to the current Plan Year and any action plans for
achieving favorable testing results now and in the future.
If the plan is closed to new entrants while HCEs continue to accrue benefits, discuss the
impact of the SECURE Act on testing. State whether or not the plan qualifies for testing
relief due to the SECURE Act or if it has yet to be determined. If the SECURE Act relief
does not apply, provide the approximate length of time the plan is expected to continue to
pass testing. If the plan is projected to fail, provide the year is the plan projected to fail? If
the plan is closed, provide the projected time period until the plan will need to be frozen.
Include the general lag time between a testing year and the date a test is done.

An iBenefits data call is being issued to collect the Pension Management Plan information on DB
Plans. A spreadsheet with projections should be completed for each DB Plan included in the data
call. Contractor representatives shall have a conference call with DOE to discuss the PMP Plan
unless they are advised by DOE that no call is required this year.
Questions regarding iBenefits may be directed to Anne Button at [email protected]. Any
other questions may be directed to Martin McCaulay at [email protected]; or within
NNSA to Karen Hart at [email protected].

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