Auditing Employee Benefit Plans

Auditing Employee Benefit Plans
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Master the fundamentals of auditing employee benefit plans in accordance with AICPA standards and ERISA rules and regulations. Written by a member on the expert panel for employee benefit plans, this book is designed to give an understanding of the requirements and audit procedures related to defined contribution, defined benefit, and health and welfare plans to help accountants more effectively plan and carry out their audit. Topics include: FASB ASU 2017-06, which significantly impacted master trust accounting, reporting and disclosures for employee benefit plans PCAOB adopted AS 3101 in 2017 which resulted in significant changes to the existing auditor's report. New insert for SAS No. 136, Forming an Opinion and Reporting on Financial Statements of Employee Benefit Plans Subject to ERISA

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Josie Hammond. Auditing Employee Benefit Plans

Table of Contents

Guide

Pages

AUDITING EMPLOYEE BENEFIT PLANS

Chapter 1 Employee Benefit Basics. Learning objectives

Introduction

Plan as defined by ERISA

Welfare plans

Pension plans

Knowledge check

Plans as defined by GAAP. Defined contribution and defined benefit

Exhibit 1-1 Defined contribution and defined benefit

Popular plan types. Pension plans. Defined contribution plans. Profit-sharing plans

Stock bonus plans

401(k) plans

403(b) plans

457 plans

Employee stock ownership plans

Money purchase pension plans

Defined benefit plans. Traditional defined benefit plans

Cash balance plans

Welfare benefit plans

Unfunded, insured, or funded

401(h) accounts

Cafeteria plans

Knowledge check

Tax compliance elements

Formation

Eligibility

Nondiscrimination

Vesting

Example 1-1

Example 1-2

Distributions

Plan termination or merger

Relief for violation

Knowledge check

Key plan operational concepts. Fiduciary conduct

Direct filing entities

Single, multi-, and multiple employer plans

Unrelated business income tax

Understanding the plan under audit

Exhibit 1-2 Unique audit considerations by plan type

Exhibit 1-3 Tax considerations in an employee benefit plan audit

Exhibit 1-4

Knowledge check

Notes

Chapter 2 Accounting and Reporting Standards. Learning objectives

Introduction

Knowledge check

Applicable guidance

FASB ASC 960, plan accounting: Defined benefit pension plans

FASB ASC 962, plan accounting: Defined contribution pension plans

FASB ASC 965, Plan accounting: Health & welfare benefit plans

Fair value measurements. FASB ASC 820, fair value measurement

FASB ASC 825, financial instruments

Knowledge check

Financial statements

Knowledge check

Investment valuation and income recognition

Accounting and reporting for investment contracts

Accounting and reporting for contributions

EBSA enforcement initiative

Notes receivable from participants (participant loans)

Operating assets

Accrued liabilities

Accounting for uncertainty in income taxes

Knowledge check

Plan mergers

Terminating plans

Going concern

Subsequent events

Knowledge check

Recent developments

Financial instruments

Definition of nonpublic entity

Plan accounting: Master trust reporting—FASB ASU No. 2017-06

Codification Improvements – FASB ASU No. 2018-09

Fair Value Measurement - FASB ASU No. 2018-13

Chapter 3 Reporting and Audit Requirements. Learning objectives

Introduction

Audit requirement

Understanding the plan under audit: Plan versus trust

Exemptions: Audit. General exemption

Small plans

80-120 participant rule

Unfunded or insured plans

ERISA 103(a)(3)(C) limited scope exemption

Knowledge check

Regulatory reporting and disclosure requirements for pension and welfare plans

Exemptions: Filing

Deadlines and extensions

Short plan years

The audit guide

ERISA versus GAAP

Knowledge check

Audit considerations

Independence

Common audit concerns or deficiencies

Professional ethics violations

EBSA inspection programs

AICPA employee benefit plan audit quality center

Issues related to participant data

Issues related to limited-scope audits

Issues related to investments

Issues related to supplemental schedules

Miscellaneous issues. Documentation

Planning and internal controls

Sample sizes

Knowledge check

Using the work of internal auditors

Recent developments

Note

Chapter 4 Audit Planning. Learning objectives

Introduction

Key parties

Knowledge check

Client acceptance. Client and engagement team evaluation

Engagement letter

HIPAA considerations

Knowledge check

Scope and timing

Nature and scope

Timing

Knowledge check

Gaining an understanding of a plan, its environment, and its internal controls

Understanding a plan (the entity)

Understanding a plan’s environment

Understanding a plan’s internal controls

Internal controls at the plan sponsor

Internal controls at service centers

Knowledge check

Risk assessment

Engagement risk

Fraud risk

Audit risk

Identification of significant risks

Accounting estimates

Audit team discussion

Materiality

Design further audit procedures in response to assessed risks

Knowledge check

Audit documentation

Analytical procedures

All plans

Defined benefit pension plans

Health and welfare plans

Initial audit procedures

Chapter 5 401(k) and Other Defined Contribution Pension Plans (Except ESOPs) Learning objectives

Introduction

Determination of benefit amount

Net assets available for benefits

Changes in net assets available for benefits

Investments

Investment types and measurement or valuation

Auditing investments in a defined contribution pension plan

Auditing of unique types of investments. Discretionary trust

Common collective trusts

Mutual funds

Master trusts

Contracts with insurance entities

Derivatives and hedging activities

Real estate

Limited partnerships

Nonpublicly traded stock and employer securities

Knowledge check

Contributions receivable

Auditing contributions receivable

Notes receivable from participants

Knowledge check

Other operating assets

Cash

Accrued liabilities

Investment income

Knowledge check

Contribution revenue

Auditing contributions received

Knowledge check

Participant data and participant accounts

Auditing participant data

Auditing participant accounts

Knowledge check

Participant-directed versus self-directed

Benefit payments

Auditing benefit payments

Present and future ability to pay benefits

Expenses

Auditing plan expenses

Knowledge check

Financial statement presentation and required disclosures

403(b) plans

Case study—participant accounts and allocations

Debrief

Information needed to begin the planning process:

What could go wrong?

Note

Chapter 6 Defined Benefit Pension Plans. Learning objectives

Introduction

Determination of benefit amount

Financial statements

Net assets available for benefits

Changes in net assets available for benefits

Accumulated plan benefits

Changes in accumulated plan benefits

Knowledge check

Investments and investment income

Knowledge check

401(h) accounts

Knowledge check

Funding

Knowledge check

Participant data and plan obligations

Benefit payments

Expenses

Financial reporting and disclosure

Plan transfers (plan mergers, spin-offs, and other transfers)

Terminations

Example 6-1 Plan termination

Knowledge check

Note

Chapter 7 Health and Welfare Plans. Learning objectives

Introduction

Defined contribution versus defined benefit

Challenges in auditing a health and welfare plan. Plan versus trust

Plan document

Claims processor’s understanding of HIPAA

Lack of SOC 1® reports for claims processor

Knowledge check

Components of the financial statements of a welfare benefit plan

Statement of net assets available for benefits

Investments

Cash

Statement of changes in net assets available for benefits

Contribution income

Benefits paid

Administrative expenses

Statement of plan benefit obligations

Claims payable

Postemployment benefit obligations and postretirement benefit obligations

Statement of changes in plan benefit obligations

Knowledge check

Unique features of a health and welfare benefit plan

Rebates receivable

Stop-loss refunds receivable

Postemployment benefit obligations

COBRA contributions

Retiree contributions

Premium contributions

Claims paid

Claims payable

Incurred but not reported (IBNR) claims

Accumulation of eligibility credits

Participant data

Medicare rebates

Knowledge check

Disclosure requirements. Description of the plan

Accounting policies

Use of estimates

Investment valuation

Postretirement benefits

Other benefits

Investment transactions

Other disclosures

Medicare subsidy Act

Multiemployer plans

Single employer plans

Reporting requirements

Chapter 8 Other Auditing Considerations. Learning objectives

Introduction

Related party and party in interest transactions

Audit procedures

Example 8-1 Party in interest transactions — both exempt and nonexempt

Financial reporting

Knowledge check

Prohibited transactions

Untimely deposits of employee deferrals

Knowledge check

ERISA supplemental schedules

Example 8-2 Typical supplemental schedules

Effects of information omitted from ERISA schedules

Knowledge check

Form 5500 information consistency with financial statements

Tax status

Knowledge check

Auditing corrective actions

Certified information

Investment confirmations

Knowledge check

Going concern

Knowledge check

Chapter 9 Wrapping Up. Learning objectives

Introduction

Commitments and contingencies

Knowledge check

Subsequent events

Knowledge check

Representation letter from management

Knowledge check

Communication of internal control-related matters identified in an audit. AU-C section 265, communicating internal control related matters identified in an audit (AICPA, professional standards)

Form of communication

Knowledge check

Management advice letter considerations

Communication with those charged with governance

Significant findings from the audit

Knowledge check

Appendix A ILLUSTRATIVE FINANCIAL STATEMENTS AND DISCLOSURES FOR A DEFINED CONTRIBUTION PLAN WITH PARTICIPANT-DIRECTED AND NONPARTICIPANT-DIRECTED INVESTMENT PROGRAMS

Exhibit C-1

Exhibit C-2

Exhibit C-3. XYZ Company 401(k) plan notes to financial statements. A. Description of plan

B. Summary of accounting policies. Basis of accounting

Use of estimates

Investment valuation and income recognition

Notes receivable from participants

Excess contributions payable

Payment of benefits

Expenses

Subsequent Events

C. Fair value measurements

D. Nonparticipant-directed investments

E. Group annuity contract with National Insurance Company

F. Rollovers contributions

G. Related-party transactions and party in interest transactions

H. Plan termination

I. Tax status

J. Risks and uncertainties

K. Reconciliation of financial statements to Form 5500

Appendix B ILLUSTRATIVE FINANCIAL STATEMENTS AND DISCLOSURES FOR A DEFINED BENEFIT PLAN ASSUMING AN END-OF-YEAR AND BEGINNING-OF-YEAR BENEFIT INFORMATION DATES

I. Illustrations Assuming an End-of-Year Benefit Information Date. Exhibit E-1. C&H Company Pension Plan Statements of Net Assets Available for Benefits

Exhibit E-2. C&H Company Pension Plan Statement of Changes in Net Assets Available for Benefits

Exhibit E-3

C&H Company Pension Plan Statements of Accumulated Plan Benefits

Exhibit E-4. C&H Company Pension Plan Statement of Changes in Accumulated Plan Benefits

II. Illustrations Assuming a Beginning-of-Year Benefit Information Date. Exhibit E-5. Note

C&H Company Pension Plan Statements of Changes in Net Assets Available for Benefits (If a beginning-of-year benefit information date is selected)

Exhibit E-6. C&H Company Pension Plan Statement of Accumulated Plan Benefits (If a beginning-of-year benefit information date is selected)

Exhibit E-7. C&H Company Pension Plan Statement of Changes in Accumulated Plan Benefits (If a beginning-of-year benefit information date is selected)

Note

Exhibit E-8. C&H Company Pension Plan Notes to Financial Statements5. A. Description of Plan

B. Summary of Accounting Policies

C. Actuarial Present Value of Accumulated Plan Benefits

D. Plan Termination

E. Fair Value Measurements

F. Interest in C&H Master Trust

Note

Note

G. Guaranteed Investment Contract With National Insurance Company

H. Derivative Instruments

I. Master Netting Agreements

J. Securities Lending10

K. Risks and Uncertainties

L. Plan Amendment

M. Tax Status

N. Related-Party and Party in Interest Transactions

O. 401 (h) Account

P. Reconciliation of Financial Statements to Form 550012

Q. Subsequent Events

I. Illustrations Assuming an End-of-Year Benefit Information Date. Exhibit E-1. C&H Company Pension Plan Statements of Net Assets Available for Benefits

Exhibit E-2. C&H Company Pension Plan Statement of Changes in Net Assets Available for Benefits

Exhibit E-3. Note

C&H Company Pension Plan Statements of Accumulated Plan Benefits

Exhibit E-4. C&H Company Pension Plan Statement of Changes in Accumulated Plan Benefits

II. Illustrations Assuming a Beginning-of-Year Benefit Information Date. Exhibit E-5. Note

C&H Company Pension Plan Statements of Changes in Net Assets Available for Benefits (If a beginning-of-year benefit information date is selected)

Exhibit E-6. C&H Company Pension Plan Statement of Accumulated Plan Benefits (If a beginning-of-year benefit information date is selected)

Exhibit E-7. C&H Company Pension Plan Statement of Changes in Accumulated Plan Benefits (If a beginning-of-year benefit information date is selected)

Note

Exhibit E-8. C&H Company Pension Plan. Notes to Financial Statements17. A. Description of Plan

B. Summary of Accounting Policies

C. Actuarial Present Value of Accumulated Plan Benefits

D. Plan Termination

E. Fair Value Measurements

Transfers Between Levels

Changes in Fair Value of Level 3 Assets and Related Gains and Losses

Quantitative Information about Significant Unobservable Inputs Used in Level 3 Fair Value Measurements

Fair Value of Investments that Calculate Net Asset Value

F. Interest in C&H Master Trust

Note

Note

G. Guaranteed Investment Contract With National Insurance Company

H. Derivative Instruments

I. Master Netting Agreements

J. Securities Lending22

K. Risks and Uncertainties

L. Plan Amendment

M. Tax Status

N. Related-Party and Party in Interest Transactions

O. 401 (h) Account

P. Reconciliation of Financial Statements to Form 550024

Q. Subsequent Events

Notes

Appendix C ILLUSTRATIVE FINANCIAL STATEMENTS AND DISCLOSURES FOR A HEALTH AND WELFARE PLAN

Exhibit F-1. Allied Industries Health Care Benefit Plan Statements of Net Assets Available for Benefits December 31, 20X1 and 20X0

Exhibit F-2. Allied Industries Health Care Benefit Plan Statement of Changes in Net Assets Available for Benefits Year Ended December 31, 20X1

Exhibit F-3. Allied Industries Health Care Benefit Plan Statements of Benefit Obligations December 31, 20X1 and 20X0

Exhibit F-4. Allied Industries Health Care Benefit Plan Statement of Changes in Benefit Obligations Year Ended December 31, 20X1

Exhibit F-5. Allied Industries Health Care Benefit Plan Notes to Financial Statements. A. Description of Plan

B. Summary of Accounting Policies

C. Postretirement and Postemployment Benefit Obligations

D. Claims Incurred but not Reported

E. Certified Investments

F. Fair Value Measurements

G. Administrative Expenses

H. Tax Status

Note

I. Termination of the Plan

J. 401(H) Account

Note

K. Reconciliation of Financial Statements to Form 5500

L. Related-Party Transactions

M. Risks and Uncertainties

Exhibit F-1. Allied Industries Health Care Benefit Plan Statements of Net Assets Available for Benefits December 31, 20X1 and 20X0

Exhibit F-2. Allied Industries Health Care Benefit Plan Statement of Changes in Net Assets Available for Benefits Year Ended December 31, 20X1

Exhibit F-3. Allied Industries Health Care Benefit Plan Statements of Benefit Obligations December 31, 20X1 and 20X0

Exhibit F-4. Allied Industries Health Care Benefit Plan Statement of Changes in Benefit Obligations Year Ended December 31, 20X1

Exhibit F-5. Allied Industries Health Care Benefit Plan Notes to Financial Statements. A. Description of Plan

B. Summary of Accounting Policies

C. Postretirement and Postemployment Benefit Obligations

D. Claims Incurred but not Reported

E. Certified Investments

F. Fair Value Measurements

G. Administrative Expenses

H. Tax Status

Note

I. Termination of the Plan

J. 401(H) Account

Net Assets Available for Postretirement Health and Welfare Benefits in 401(h) Account

Changes in Net Assets in 401(h) Account

K. Reconciliation of Financial Statements to Form 5500

L. Related-Party Transactions

M. Risks and Uncertainties

Notes

Appendix D ILLUSTRATIVE SUPPLEMENTAL SCHEDULE OF ASSETS

Notes

Appendix E ILLUSTRATIVE SUPPLEMENTAL SCHEDULE OF REPORTABLE TRANSACTIONS

Appendix F ILLUSTRATIVE EXAMPLE OF AN ENGAGEMENT LETTER FOR A 401(K) EMPLOYEE BENEFIT PLAN AUDIT ENGAGEMENT

Exhibit 2-5

Note

Notes

Appendix G SMALL PENSION PLAN AUDIT WAIVER DECISION TREE

Exhibit 2-4 Small pension plan audit waiver (SPPAW) summary (applies to plan years beginning on or after April 18, 2001)

Appendix H REPORT MODIFICATIONS CHART

Notes

Appendix I PENSION PLAN AUDIT DECISION TREE

Exhibit 2-21 Pension audit plan decision tree

Note

Appendix J ILLUSTRATIVE SUPPLEMENTAL SCHEDULE OF DELINQUENT PARTICIPANT CONTRIBUTIONS

Employee Benefit Plans Glossary

Accounting and Auditing Glossary

Index

AUDITING EMPLOYEE BENEFIT PLANS

Solutions. Chapter 1. Knowledge check solutions

Chapter 2. Knowledge check solutions

Chapter 3. Knowledge check solutions

Chapter 4. Knowledge check solutions

Chapter 5. Knowledge check solutions

Chapter 6. Knowledge check solutions

Chapter 7. Knowledge check solutions

Chapter 8. Knowledge check solutions

Chapter 9. Knowledge check solutions

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BY JOSIE HAMMOND, CPA, AND MELISSA FRIVOLD, CPA

.....

403(b) plans have slightly different eligibility standards for employee salary deferrals, which are to be documented in the plan. Few exclusions from eligibility are permitted for employee salary deferral contributions. The standards described previously are permissible with respect to employer contributions to a 403(b) plan.

Welfare plans do not currently have specific eligibility standards that are set by law. The plans, however, must define what standards apply for plan participation. This is currently a confusing area as the Affordable Care Act (ACA) gradually phases in. There are new rules with respect to when dependents lose their coverage; a new nondiscrimination standard that is not yet in force; and mandatory coverage features in 2014, for which some temporary relief has been granted generally through the end of the 2016 plan year. A violation of these evolving rules may change the tax status of a provided benefit or subject the employer to a penalty, but in general, they will not change the plan’s obligations unless the plan sponsor chooses to amend the plan to revise the definition of eligibility.

.....

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