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  • A BUYERS GUIDE

    Hiring the

    for your Benefit PlanRIGHT AUDITOR

    PLAN AUDITS:

  • This guide provides a general outline of what to consider when hiring an auditor. Clark Schaefer Hackett advisors can provide additional insight into how a properly conducted audit, and an ongoing relationship with your audit firm, can benefit your organization.

    Plan Audits: A Buyers Guide Hiring the Right Auditor for your Benefit PlanCopyright 2015

    Published by Clark Schaefer Hackettcshco.com

    All rights reserved. Except as permitted under U.S. Copyright Act of 1946, no part of this publication may be reproduced, distributed, or transmitted in any form or by any means, or stored in a database or retrieval system, without prior written permission of the publisher.

    A BUYERS GUIDE PLAN AUDITS:

  • Time to evaluate

    Clark Schaefer Hackett created this buyers guide to help you and other plan

    fiduciaries make an informed decision when hiring a quality auditor for your

    employee benefit plan audit.

    According to federal law, sponsors of large employee benefit plans are required to

    complete an audit as part of their fiduciary duties. However, a quality audit doesnt

    begin or end with this requirement. The auditor-sponsor relationship needs to be

    more comprehensive, going beyond problems identified via an audit by delving into

    the solutions.

    A willingness to work year-round to solve the common problems of plan

    administration is the hallmark of a skilled auditor. This guide will detail the

    importance of a quality auditor, the risks associated with a poor quality audit, and

    how you can identify the best auditor for your plan.

  • You have fiduciary responsibilities

    When does a plan need an audit?

    Its all about quality

    Saving you from errors

    Traits of a quality auditor

    Finding the right auditor

    What sets Clark Schaefer Hackett apart?

    Auditors should add value

    Resources

    Table of Contents1

    3

    5

    7

    9

    11

    13

    15

    16

  • You have fiduciary responsibilities As outlined by the Employee Retirement Income Security Act (ERISA,) plan

    fiduciaries include any individual named in the plan document as a fiduciary and

    those who have discretionary authority over plan management or plan assets. Plan

    fiduciaries have a standard of conduct and various responsibilities imposed by

    ERISA.

    These responsibilities include:

    Acting in the best interest of the plan participants

    Acting with care, skill, prudence and diligence

    Avoiding prohibited transactions

    Following plan documents

    Hiring service providers

    Monitoring investments and fee reasonableness

    When hiring a service provider for day-to-day operations, ask the provider for:

    An overview of the firm

    The firms services and experience with benefit plans

    The firms business practices

    Identity and experience of the team servicing the account

    Fee structure

    1 Plan Audits: A Buyers Guide

  • When monitoring the service provider, your responsibilities include:

    Evaluating service provider performance

    Reading reports

    Comparing fees to the service agreement

    Following up on any complaints from participants

    Note that the plan sponsors responsibility is not always to find the lowest-cost

    provider. Instead, the responsibility is to evaluate the providers quality and level of

    service and compare them against the fees. Hiring the right expert is paramount in

    order to protect the plan and the fiduciaries.

    The U.S. Department of Labor has a number of guides and resources about fiduciary

    responsibilities and ERISA. See Resources A and B, page 16.

    How do you protect the

    plan and the fiduciaries?

    Plan Audits: A Buyers Guide 2

  • When does a plan need an audit?In general, an audit is required when an employer has a qualified benefit plan with

    more than 100 active participants at the beginning of the plan year.

    Active participants include:

    Eligible participants those meeting eligibility requirements

    regardless of plan participation

    Termed and retired participants

    Beneficiaries of deceased participants

    Plans with more than 100 participants are usually considered large plans, while those

    with fewer than 100 are considered small plans.

    Qualified plans must file a Form 5500 annually and will file as either a large or small

    plan. ERISA requires large plans to attach audited financial statements to the Form

    5500 filing.

    However, plans that fluctuate over and under 100 participants arent required to

    switch categories. This is called the 80-120 participant rule.

    Plans that have within 80 and 120 participants can opt to stay in the same category

    as in the prior year, while plans under 80 participants file as small and plans over

    120 file as large.

    3 Plan Audits: A Buyers Guide

  • The categorization of large or small plan isnt always set in stone. In fact, a plan

    sponsor has the ability to manage the number of plan participants. Certain plan

    provisions and hiring decisions can impact the categorization of the plan as large.

    Here are a few plan aspects to examine:

    Terminated participants You can make automatic benefit payments to

    terminated participants with nominal balances to reduce the participant

    count. Follow plan document provisions or amend your plan to set a

    threshold of automatic cash-out balances (e.g., $1,000 or $5,000). Then, the

    participants balance can be distributed, rolled into another qualified plan or

    placed in an IRA without having to track down the participant.

    Eligibility requirements Consider a high-turnover workplace, where its

    somewhat common for employees to leave within their first six months of

    employment. Even if they are not actively deferring into the plan, these

    employees can still count toward the size of the plan. One way to manage

    this is to consider amending your eligibility requirements so that employees

    must have six months of service before they can participate. This can

    reduce overall plan counts and administrative burden.

    Count projections Use the 80-120 rule to your advantage. If you hover

    around 100 participants, it may be more cost effective to remain a small or

    large plan, instead of bouncing back and forth - needing an audit one year

    and not the next.

    Plan Audits: A Buyers Guide 4

  • Its all about qualityAn audit provides a third-party, independent report summarizing the plan activity,

    investments and provisions, which enables the plan sponsor, participants and

    regulators to assess the plans ability to pay future benefits to participants. A quality

    audit enables plan fiduciaries to execute fiduciary responsibilities and demonstrate

    plan oversight.

    During a plan audit, the auditors gain an understanding of plan controls and conduct

    compliance tests of critical plan provisions such as eligibility, employee/employer

    contribution calculations, timeliness of contribution remittances, loans and benefit

    payments. Plan auditors also review tax filings and non-discrimination testing results

    that are required for the plan to maintain a qualified status.

    Here are ways a qualified audit team can help a plan sponsor:

    Recommending plan control improvements or process efficiencies

    Identifying operational errors to ensure participants are receiving promised

    benefits

    Assisting with error correction

    Delivering regular accounting and regulatory updates

    Providing IRS or DOL audit assistance

    Presenting audit information at trustee meetings

    Offering access to national benefit experts

    In short, a quality audit reduces risk and offers plan fiduciaries peace of mind.

    5 Plan Audits: A Buyers Guide

  • Completing and attaching the audited financial statements to a large plans Form

    5500 filing is a fiduciary requirement. But plan sponsors need to be focused on more

    than just compliance. When you take your eye off of quality, you put yourself at risk.

    Plan sponsors are at a higher risk of the following as a result of an incomplete,

    inaccurate or untimely audit:

    Fines (for which fiduciaries have personal liability)

    Unidentified plan operations failures

    Increased liability

    Fraud

    Missed cost savings

    A poor quality audit can lead to rejection of the Form 5500 filing by the DOL, or

    additional scrutiny of your plan by regulators due to inaccurate reporting.

    When you take your eye off

    quality, you put yourself at risk.

    Plan Audits: A Buyers Guide 6

  • Saving you from errorsPlan administration can be complex and cumbersome, so its not surprising that

    errors can surface. And if audited by the IRS or DOL, correcting identified errors is

    generally more costly and time consuming than having a qualified auditor discover

    and help management correct them at the outset.

    Here are the four most common errors identified during plan audits:

    1. Delinquent remittance of employee contributions - Delinquent remittance

    of employee contributions is a prohibited transaction and has to be reported

    separately to the DOL. Partici