The Overlap Between Missing Participants and Unidentified Deaths

By: John Bikus, The Berwyn Group

Fund members will gain insight into how accurate, continuously validated participant data is foundational to good plan governance. The article highlights how integrating death identification and participant location efforts strengthens oversight, reduces risk, and supports more defensible fiduciary decision-making.

For many plan sponsors, missing participant searches and death audits are treated as two separate administrative functions. One focuses on locating individuals, the other on identifying deceased participants, and preventing improper payments.

As expectations around fiduciary responsibility continue to evolve, a growing number of plan sponsors are recognizing that the line between “missing” and “deceased” participants is often blurred, and that treating these issues independently can introduce risk.

When “Missing” Doesn’t Mean Unreachable

The traditional definition of a missing participant centers on failed outreach, including returned mail, inactive accounts, outdated contact details, or uncashed checks. But that definition assumes the individual is still living.

In reality, that is not always the case.

Across more than 1,500 plan populations analyzed by Berwyn in 2025, 73.6% were missing at least one key data element, such as name, Social Security number, date of birth, or current address. These gaps do more than hinder outreach. They limit a plan’s ability to locate participants and understand their status.

As a result, what appears to be a participant location issue can become more complex. Plans may continue outreach for individuals who are no longer living, while their status remains unresolved.

This is why treating death audit and participant location as separate efforts creates risk. Without accurate data and validated death information, plans are not just searching for missing participants; they are operating without a clear understanding of who belongs in the population.

Why This Distinction Matters

At a surface level, the difference between a missing and deceased participant may seem operational. In practice, it has broader implications.

• Continued payments to deceased participants can lead to overpayments that are difficult, or impossible, to recover.
• Ongoing outreach efforts directed toward deceased individuals create inefficiencies and unnecessary costs.
• Incomplete or inaccurate records can complicate audits and regulatory reviews.
• Documentation gaps may make it difficult to demonstrate that appropriate steps were taken to maintain accurate census data.

As regulatory scrutiny increases, plan sponsors are expected not only to make a reasonable effort to locate participants, but also to maintain accurate and validated records. Without a clear understanding of whether a participant is living, even well-intentioned search efforts may fall short of that expectation.

Where Traditional Approaches Fall Short

Many plans rely on periodic death audits and ad hoc locate efforts. While each serves a purpose, they are often conducted independently, using different data, methods, and timelines.

This separation creates blind spots.

A locate process may find a new address without confirming whether the individual is still living. A death audit may identify decedents but remain disconnected from ongoing outreach or record updates.

Not all data is created equally. Some approaches rely on unverified or single-source data, increasing uncertainty and manual review. As a result, plan sponsors may receive results that suggest an outcome but lack the validation needed to act with confidence.

The Case for a More Integrated Approach

To address these gaps, many organizations are shifting toward continuous data validation, approach that integrates multiple data sources, applies validation methodologies, and maintains ongoing visibility into participant status. This type of strategy is designed to answer two critical questions at the same time:

• Can the participant be located?
• Can the participant’s status be confidently verified?

Answering one without the other leaves room for error.

By combining death identification, data enrichment, and participant location efforts into a unified process, plan sponsors can reduce uncertainty, improve data accuracy, and create a more defensible administrative framework.

Looking Ahead

As the industry continues to place greater emphasis on data integrity and fiduciary accountability, the definition of effective missing participant management is expanding.

It is no longer limited to locating individuals when outreach fails. It increasingly requires a more comprehensive understanding of participant status, supported by accurate, validated, and continuously maintained data.

For plan sponsors, this raises an important question:

Is your current process designed to find participants, or to fully understand them?

In many cases, the difference between those two approaches is where risk and opportunity reside.

About the author: John Bikus, President of The Berwyn Group, leads the company’s efforts to bring accuracy, validation, and innovation to death audit and participant location services for pension funds. He previously co-founded and grew two pioneering data companies — ObitData.com and Legacy.com — which helped transform how organizations and consumers access and verify obituary information.