It seems a good, balanced article. Though it presents arguments from proponents as well as opponents of "church plans," overall it presents our arguments well. Since employees in particular are reluctant to speak out for fear of retaliation, the publicity is very welcome. The issue now enjoys a much higher level of awareness, and as they say, sunlight is the best disinfectant.
However, we had to chuckle at the comments of church plan officials who characterize federal pension requirements as "excessive administrative burdens." The Pension Benefit Guaranty Corporation insurance premiums for ERISA plans are exceedingly low—on the order of $35 per participant per year—because they cover every plan in the country (except church plans). This is a great bargain, especially for an underfunded plan! For a church plan that's only 64% funded to find an insurance company willing to underwrite an individual policy would be exceedingly difficult, and the insurance would cost a fortune.
We received the following anonymous comment after the article appeared:
As a former and vested employee of SPUH I found my self totally blindsided by the news about the church plan notice. (I just noticed the article on nj.com on 1/22 and did a search on the subject.) As a vested plan participant shouldn't I have received a copy of the IRS required notice? If SPUH neglected to send a notice to all vested participants, would this be grounds for extending the comment period?We don't know. We believe they've done enough to pass the IRS requirement to notify "interested persons." This makes it vitally important to compose and send your comment letter as soon as possible, and ask all the former and current employees you know to visit this site and do the same.
