How are premium e-filings certified/signed?
The premium filing certification requirements have not changed with the implementation of electronic filing. The plan administrator must always certify each filing while the enrolled actuary must certify certain types of filings. What electronic filing has changed is how the certifications are completed. For filings that are prepared via the My PAA data entry screens and for software-prepared filings that are imported into the My PAA screens, all certifications are made on the My PAA screens. This is why each certifier must have an account (e.g., user ID and password) and the plan must be included within each person’s account. For software-prepared filings that are uploaded into My PAA, the plan administrator or enrolled actuary may certify directly on the My PAA upload screen if he/she is the uploader. If the plan administrator or enrolled actuary is not the uploader, the certification is typically made on a paper copy of the filing information printed from the software. Certified cop
