Art of the Qualified Plan Audit

Do You Have a Template for a Request for Proposal (RFP) for a 401(k)/403(b) Plan? Almost every time I present an educational seminar, at least one attendee asks me if I have a template for a retirement plan audit RFP. After discussing the importance of selecting a quality plan auditor and providing a list of … Continued

This blog was updated 12.19.2025 with enhanced examples.  Background Effective January 1, 2026, catch-up eligible participants who are High Earners must make catch-up contributions on the Roth basis. The industry has been using the term Highly Paid Individuals, so we will use both terms for the sake of clarity and consistency with other published articles. … Continued

In Summary Applicability and Exemptions: Effective for plan years after December 31, 2024, new plans established after December 29, 2022, must implement automatic enrollment; however, exemptions apply to “grandfathered” pre-enactment plans, businesses with 10 or fewer employees, companies in business for less than three years, and governmental, church, or SIMPLE plans. Contribution and Escalation Mechanics: … Continued

In Summary Mandatory Roth Contributions for High Earners: Effective January 1, 2026, “High Earners” (defined as participants with prior-year FICA wages exceeding $150,000) are required to make all catch-up contributions—including the new “Super Catch-Up” for participants aged 60–63—on a Roth (after-tax) basis. Exclusions and Plan Limitations: The mandate strictly applies to employees with W-2 FICA … Continued

In Summary The 80-120 Rule for Audit Requirement: A retirement plan’s need for an annual audit is determined by counting participants with account balances on the first day of the plan year. The 80-120 rule is an exception that allows a plan with 80 to 120 participants to file as a small plan (no audit) … Continued

Posted by Christopher J. Ciminera, CPA IKYMI: It’s with great pleasure that we congratulate Maria Hurd, CPA, RPA, our fearless employee benefit plan practice group leader and the guiding star for myself, Stacey Snyder, Saaib Uppal, Tyler Starr, and many others, for being recognized on Forbes’ List of America’s Best-in-State CPAs. This list is a … Continued

In Summary Unclear Deadlines for 401(k) Deferrals: The Department of Labor (DOL) regulations for 401(k) deferral deposits are unclear, using “earliest” and “reasonably” rather than a firm deadline. While small plans (under 100 accounts) have a 7-day safe harbor, large plans do not. As a result, many large plans adopt a 3-day industry standard, which … Continued

In Summary Foundational Plan Governance: Auditors will require all core legal and governance materials, such as the executed plan document, the most recent IRS determination letter, committee minutes, proof of the ERISA fidelity bond, and copies of all service provider agreements. Financial Reporting: The audit relies on detailed financial data, including the draft Form 5500, year-end … Continued

In Summary Funded Plans, the Audit Requirement: The single most important factor determining if a large welfare plan needs a CPA audit is its funding status. If a plan uses a separate trust account (such as a 501(c)(9) VEBA) to hold assets or pay benefits—making it “funded”—it must undergo an audit of the entire plan … Continued

In Summary SECURE 2.0 Expands Coverage: The SECURE 2.0 Act’s Long-Term Part-Time (LTPT) rules, effective for 403(b) plans as of January 1, 2023, require employers to permit employees to make elective deferrals if they work 500-999 hours annually for two consecutive years (starting with the 2023 plan year) and have reached age 21. Impact on … Continued