Why Data Integrity Matters for Plan Sponsors

Tracking and managing an employee population—regardless of the industry—is no easy feat, says John Bikus, president of population data management company the Berwyn Group.

For plan sponsors especially, having inaccurate or incomplete data on participants, beneficiaries and retirees can result in high costs, including overpayments to deceased participants, as well as preparations for—and penalties resulting from—audits. The cost may also affect a beneficiary waiting to receive significant benefit due to a pensioner’s death, unknown to the sponsor.

In 2021, the Department of Labor issued three pieces of guidance specifically focused on missing participants. In the guidance on best practices, the DOL indicated that plan sponsors should take the following steps to deal with the missing participant issue:

• maintain accurate census information;
• implement effective communication strategies;
• conduct missing participant searches; and
• document procedures and actions.

The DOL has stated that failure to locate a missing participant—meaning also a failure to distribute benefits when those are due and a failure to distribute annual participant disclosures—is a breach of fiduciary duty. To remain legally compliant, data integrity may be more important to plan sponsors than ever.

Bikus says 7.5% of the records provided by plans to Berwyn’s death auditing solution, CertiDeath, are either incomplete or accurate. His firm’s job is to identify and update the data that comprise those discrepancies, be it inaccurate Social Security numbers, beneficiary information, dates of birth, mailing addresses or death records.

Some common reasons for inaccurate data include: participants relocating in retirement; plan sponsors misunderstanding a deceased participant’s lack of response to communication as indicative of a “missing participant”; and a lack of resources to track participants—the last more common among government plans than others.

One of Berwyn’s population management solutions, CertiCensus, deploys more than 1million mailings and calls per year to locate participants. The product creates an audit trail and makes sure participant data is accurate and updated.

“If someone can’t be found, there’s a process [defined contribution plan sponsors] are able to document to the [Pension Benefit Guaranty Corporation] through CertiCensus that says, ‘Here are the steps we took,’” Bikus explains. “It ensures to the PBGC that they’ve made the best possible effort” to locate the missing participants.

While PBGC audits are performed only on defined benefit plans, defined contribution plans may participate in the PBGC’s Missing Participants Program, which helps connect missing participants with their benefits from terminated plans that are closing out. The PBGC works to locate participants and beneficiaries who were missing when their plans ended. When found, the PBGC either provides the benefit or provides information about where the participant’s account is held.

Aon found in its 2026 Global Pension Risk Transfer Survey that 56% of terminating plan sponsor respondents said they were likely to implement data cleanup in the next two years or have already done so.

Bikus says validating participant, beneficiary and retiree information—not just seeking it out—is critical.

“My advice to any plan sponsors, regardless of whether they’re thinking about outsourcing [the data validation] or doing it internally, is to ask, ‘Can everything can be measured?’” Bikus says. “‘What percentage of identifiable data are we sure are accurate?’”

Aon fielded responses for the 2026 Global Pension Risk Transfer Survey from 88 plan sponsors between May and August 2025.