Art of the Qualified Plan Audit

In Summary High Cost of Exclusion Correction: Correcting the improper exclusion of eligible employees from making salary deferrals under the IRS’s EPCRS involves substantial employer contributions. This includes a Qualified Nonelective Contribution (QNEC) and 100% of the missed matching contribution, potentially leading to a perceived windfall for the affected participants who received their full paychecks … Continued

Posted By: Maria Hurd, CPA There is Always Room for Improvement: Proposed Revisions to Form 5500 On September 14, 2021, the U.S. Department of Labor (DOL), the Internal Revenue Service (IRS), and the Pension Benefit Guaranty Corporation (PBGC) (together “Agencies”) jointly announced a tri-agency notice of proposed forms revisions to the Form 5500 Annual Return/Report … Continued

Is your auditor a Jack of all trades, but a master of none?

Posted By: Maria T Hurd, CPA, RPA Improved EPCRS : More Self-Correction Options Inside the Box Perfection is aspirational, especially when it comes to retirement plan administration. That is why 30 years ago, in 1991, the IRS created the EPCRS (Employee Plan Compliance Resolution System), a mechanism for plan sponsors to fix mistakes. Compliance with … Continued

Posted By: Maria Hurd, CPA, RPA What Do You Check to Indicate Your Client’s Auditor Performed a Limited Scope Audit On Your Mark, Get Set, GO!, Or Don’t Go….It’s Up to You! The AICPA postponed the mandatory effective date of the new audit standard, SAS 136, until next year, but the DOL had already updated … Continued

In Summary Auditor Selection Responsibility: Plan sponsors must evaluate the qualifications of the CPA firm hired for a retirement plan audit, a challenging task given the complexity of the work. The Department of Labor (DOL) and AICPA provide resources to assist in this selection, emphasizing that the size of an audit practice and its commitment … Continued

  Maria Hurd, CPA, RPA, Christopher Ciminera, CPA, QKA,  and many members of our employee benefit plan audit team are highly sought after for speaking events. Here are a few upcoming speaking events that we thought you might be interested in attending. APRIL 19, 2021: Death, Taxes, and Retirement Plan Operational Failures – On April … Continued

In Summary Certified Value Might Not Be Valid When Limited Scope Certification Is: An ERISA Section 103(a)(3)(C) certification guarantees completeness and accuracy based on a financial institution’s ordinary business records, but this does not assure compliance with GAAP. If the custodian’s “best available information” is not fair value, a certified value is provided that auditors … Continued

Posted By Maria T. Hurd, CPA How Big Can a Retirement Plan Be and Still Qualify for the Small Plan Audit Exemption? “Define Large.” It is a question I often get from advisors hoping to get their clients out of a retirement plan audit. Until now the answer has been simple: 100 participants is the … Continued

In Summary Correction Options Exist Even if Funds Are Gone: Overpayments, which often represent a timing difference, can be corrected through the Employee Plan Compliance Resolution System (EPCRS). When a participant cannot return the money, viable alternatives include amending the 1099-R to remove favorable tax treatment, making a “make-whole” contribution to defined benefit or balance-forward … Continued