What's new - OnPoint EBP March 2023
The 2023 release of OnPoint EBP includes a substantially expanded scope to help firms audit more types of employee benefit plans subject to the Employee Retirement Income Security Act of 1974 (ERISA). Prior releases focused on 401(k) plans. With this release, firms may now audit 403(b) plans, defined benefit plans, and health and welfare benefit plans. OnPoint EBP continues to address engagements when management elects to have an audit performed pursuant to ERISA Section 103(a)(3)(C), as well as engagements not performed pursuant to ERISA Section 103(a)(3)(C), for all in-scope plan types.
403(b) plans
OnPoint EBP may be used for audits of 403(b) plans, including engagements when the plan administrator has elected to exclude some or all pre-2009 contracts or accounts meeting the conditions of DOL Field Assistance Bulletin No. 2009-02, Annual Reporting Requirements for 403(b) Plans, from the plan's financial statements, or instructed the auditor not to perform procedures on certain or all pre-2009 contracts or accounts, or both.
Defined benefit plans
GAAP allows defined benefit plans to present information regarding the actuarial present value of accumulated plan benefits in the financial statements as of either the beginning or end of the plan year. OnPoint EBP supports both options.
Additionally, employers may fund a portion of their postretirement medical benefit obligations related to their health and welfare benefit plans through a health benefit account [401(h) account] in their defined benefit plans. OnPoint EBP addresses the accounting and auditing implications of 401(h) accounts in an audit of a defined benefit plan with such a feature.
Health and welfare plans
Health and welfare benefit plans vary widely in how they are structured and the benefits they provide. OnPoint EBP may be used to audit defined benefit health and welfare plans, defined contribution health and welfare plans, and health and welfare plans that contain both defined benefit and defined contribution features in a single plan. Further, health and welfare plans in which certain retiree health benefits are funded through a 401(h) account in a defined benefit pension plan are also within the scope of OnPoint EBP.
Updated for recently issued guidance and standards
Content and guidance have been updated for the issuance of the AICPA Audit and Accounting Guide, Employee Benefit Plans (Updated as of August 1, 2022).
Revised SOC 1 type 2 report evaluation tool
The SOC 1 type 2 report evaluation tool (2005) has been reintroduced in an Excel format to enhance overall usability and allow it to be more easily replicated, if needed. The new format will enable firms with a centralized SOC review process to more easily share the completed SOC review document among engagement files. Also, an “Other” type of service organization has been added to accommodate service providers unique to health & welfare plans (i.e., claims processors).
Enhanced tool for performing preliminary and final analytical procedures
The Preliminary and final analytics document (2105) has been refined to provide additional information and more efficient analysis.
Presentation and disclosure checklist
OnPoint EBP includes a new document (1335) containing presentation and disclosure requirements and guidance for financial statements of employee benefit plans. The checklist has been tailored to encompass specific requirements related to nonpublic defined contribution, defined benefit, and health and welfare employee benefit plans from specific FASB ASC Topics. It also includes certain presentation and disclosure recommendations from the AICPA Audit and Accounting Guide, Employee Benefit Plans.
Methodology updates
This release of OnPoint EBP also includes the following significant methodology updates:
| Changes to risk assessment | |
|---|---|
| Financial reporting risk assumptions | Updated to better align with the inherent risk factors. |
| Compliance risks | A new procedure was added to the “Planned audit approach” section of each risk assessment document (2200 through 2245) related to consideration of compliance risks. This procedure is visible when a pre-populated compliance assumption is changed from “Yes” to “No.” |
| Application of FinREC guidance as it relates to revenue recognition | Removed the presumptive risk of material misstatement due to fraud related to revenue recognition and contributions. This change impacted:
|
| Contributions risk assessment | Expanded risks factors and assumptions for all plan types at Risk assessment – plan contributions (2200). |
| Other Key Updates | |
|---|---|
| Plan profile | The Plan profile document (1205) has been expanded to include additional scoping questions unique to the added plan types; content dynamically adjusts to show only procedures that are relevant to the type of plan selected at 1000 Engagement - acceptance/continuance. Procedures with the Procedures with that same icon for a health & welfare plan will instead result in placeholders, considerations, and/or disclosures being added to the Notes to the Financial Statements section in the Financial statements and auditor’s report document (1300), as the related content will vary depending on the features of the health & welfare plan being audited. Placeholders contain lightbulb guidance regarding the required disclosures. |
| Overall audit strategy | Updated the “Tax status” procedure in the Overall audit strategy document (1405) to include procedures for unrelated business taxable income, if the auditor indicates the plan may have taxable transactions. |
| IT general controls | Previously specific to the payroll cycle, the IT general controls checklist (2130) was updated to encompass all outsourced IT functions that may be relevant to an employee benefit plan. |
| Sampling | Unique sampling workbooks (2325 through 2328) were added for each type of plan. ERISA Section 103(a)(3)(C) and Non-Section 103(a)(3)(C) sampling considerations are no longer in separate sampling workbooks but have been included in the sampling workbook for each respective plan type. |
| Payroll tests of controls | The Risk assessment – participant data document (2210) no longer presumes the auditor will be testing payroll controls. If the auditor indicates they plan to test controls, Payroll test of controls workbook (3215) will be visible on the Documents page. |
| Participant data testing template | Updated to allow for the option of pay period or annual testing of payroll and participant contributions [for 401(k) and 403(b) plans]. |
icon that pertain to a 401(k), 403(b), or defined benefit plan will pre-populate draft note disclosures and/or will transfer content added by the auditor in this document to the Notes to the Financial Statements section in the Financial statements and auditor’s report document (1300).Fixes
The following list features a brief description of the issues that have been resolved in the May 4, 2023 release.
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In document 1300, Financial statements and auditor’s report, the visibility conditions attached to the Independent Auditor's Report – Non-Section 103(a)(3)(C) Audit, were updated to make that report show when certain conditions are met (e.g., on document 1000, Engagement – acceptance/continuance, “401(k) or profit sharing” is selected as the Plan type and the Audit service is identified as “Non-Section 103(a)(3)(C) audit").
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For engagements created prior to the visibility conditions being revised, if the appropriate auditor's report is not visible, it can be easily added by using the following steps. In the engagement file, open document 1300, Financial statements and auditor's report, click on the + button on the left side of the screen in the "Document Map" pane and select the appropriate auditor's report (e.g., "Independent Auditor's Report - Non-Section 103(a)(3)(C) Audit"). The "DO NOT USE" text at the top adjacent to the report heading may need to be manually deleted. If so, simply select the phrase and delete or backspace. All content within the report should appropriately appear based on selections made in document 1000, Engagement - acceptance/continuance.
The following list features a brief description of the issues that have been resolved in the April 13, 2023 release.
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In the “Sampling template – 401(k) or profit sharing plans,” document 2325, the formula to derive the appropriate sample size factor based on the assessed risk of material misstatement, expected misstatements, and stratification of the sample was corrected. The change to the formula could change previously calculated sample sizes for engagements created in the 2023 version of OnPoint EBP released March 23, 2023.
