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Finding Plain English Answers on Employee Benefit Plan Audits

If you are a CPA who audits employee benefit plans, you understand how complex they can be. You know how critical it is to make certain that you and your staff have all of the knowledge and resources you need to perform quality audits in this area. Luckily, the AICPA has several resources available to assist members in performing EBP audits.

One such resource is the Center for Plain English Accounting. I am the director of the newly launched CPEA, the AICPA’s national A&A resource center for Private Companies Practice Section member firms. Members can submit written questions to the CPEA and receive written responses and gain access to reports, alerts and webinars on A&A topics including EBP, revenue recognition and Private Company Council accounting alternatives. Watch the video below for more information on CPEA.

Every month, the CPEA receives many types of A&A inquiries. However, in the summer, we receive a higher number of EBP audit related queries because many companies receive tax extensions that delay the deadline for companies’ Form 5500 and audited financials for EBP until October 15.

Each query—and the CPEA’s response to that query—is unique in itself, because plans vary from organization to organization. Therefore, it is not a one-size-fits-all area. That is why it is so important for practitioners performing EBP audits to know where to go to find the right answers.

For example, we recently received the following query from a CPEA member:

For an employee benefit plan where there are no uncertain tax positions, would the plan be required to disclose, by year, each year that remains subject to examination by major tax jurisdictions? Alternatively, could we go with a more general note disclosure?

We suggested a more detailed disclosure, which might say something like “The Plan is subject to audits by the IRS; however, there are currently no audits for any tax periods in progress. The Plan’s management believes it is no longer subject to income tax examinations for years prior to 20X0.”

Even though the entity does not have any tax audits in process, it is helpful for users to understand which years might still be subject to examination by the Internal Revenue Service. Many times these disclosures can be overlooked where an entity has not been subject to IRS audits in the past or does not hold any uncertain tax positions.

Another question we are asked:

Does a successor auditor in a limited scope audit have to comply with the requirements in AU-C section 510 of the professional standards related to obtaining information from the predecessor auditor?

Our answer? Yes. An auditor still needs to comply with AU-C section 510.

Simply put, EBP is not an area to enter into lightly. I cannot stress enough the importance of tapping into the right resources that specifically address EBP so you can provide quality services to your clients. The AICPA has a number of resources that provide key assistance for EBP auditors. Here are three additional ones you should know about and keep on hand, if needed:

  1. The AICPA’s EBP Audit Quality Center. EBPAQC membership connects you to a community of peers through a membership center with tools and resources, regular e-alerts, a dedicated website with a robust member forum that keeps you abreast of the latest Department of Labor, accounting and auditing developments affecting your EBP audit clients.
  2. AICPA EBP Publications. The Employee Benefit Plans: Audit & Accounting Guide and the Accounting Trends & Techniques: Employee Benefit Plans are targeted toward practitioners auditing in this area.
  3. The AICPA’s Accounting and Auditing Technical Hotline. This free resource provides AICPA members with technical assistance by phone.

Conducting EBP audits can be a growth area for CPA firms. However, these specialized audits involve a level of knowledge and experience that requires dedication and diligence.   

If you’re just getting your feet wet in the EBP audit world, I encourage you to avail yourself of the additional assistance and resources offered by the AICPA.

Robert Durak, CPA, CGMA, Director, Center for Plain English Accounting, American Institute of CPAs. Bob is the AICPA’s lead staff person on accounting and attest matters affecting private companies. Prior to joining the CPEA, Bob led the AICPA's development of the Financial Reporting Framework for Small- and Medium-sized Entities and speaks frequently across the country about private company financial reporting.

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