Determining Employee Benefit Plan Size – Proposed Audit Changes

By Brett Sinsabaugh, CPA, CCA, Business Assurance & Advisory Services Senior Manager

Determining Employee Benefit Plan Size – Proposed Audit Changes

Retirement Plan Audit Changes May Be Coming in 2022

Following up on a recent article, “Employee Benefit Plans and the 80-120 Participant Rule”, we may soon see a change that would have implications on audit necessity due to Plan size.

Public Comments Requested for Proposed Form 5500 Changes

The DOL Employee Benefits Security Administration (EBSA), IRS and the Pension Benefit Guaranty Corp. (PBGC) are currently seeking public comments on proposed revisions to the Form 5500 Annual Report. Among several proposed changes, there is one that many Plan Sponsors should have on their radar. One key proposed change would seek to expand the number of defined contribution pension plans that would be eligible for small plan simplified reporting options.  This would include the conditional waiver of the independent qualified public accountant annual audit.

Public comments on the proposed change were due November 1, 2021. If the proposed changes are adopted, these generally would not be effective for some time, at minimum for plan years beginning on or after January 1, 2022.

This proposed change could have a major impact on plans which are required to file an audit opinion with their annual Form 5500 reporting.

For more information regarding the determination of Plan sizes, proposed changes, or employee benefit plan audits, please contact your Keiter Opportunity Advisor, Brett Sinsabaugh, Business Assurance and Advisory Services Senior Manager or another member of our Employee Benefit Plan Niche team.

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About the Author


Brett Sinsabaugh

Brett Sinsabaugh, CPA, CCA, Business Assurance & Advisory Services Senior Manager

Brett’s client focus is primarily in the real estate and construction industry.  He also provides audit and business assurance services to privately-held businesses to clients in the manufacturing, retail and distribution, and technology industries, as well as employee benefit plan audits and not-for-profit organizations.  Brett is a member of the Firm’s Employee Benefits team and Real Estate and Construction industry team.

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The information contained within this article is provided for informational purposes only and is current as of the date published. Online readers are advised not to act upon this information without seeking the service of a professional accountant, as this article is not a substitute for obtaining accounting, tax, or financial advice from a professional accountant.

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