Plan Compliance and Operational Audits

We work closely with plan sponsors to customize the scope and focus of each plan compliance review or operational audit.

PLAN COMPLIANCE REVIEWS

We offer a wide range of compliance services designed to help sponsors ensure their plans are in line with IRS, ERISA and PBGC regulations. Our plan compliance services include:

• Nondiscrimination testing under the follow Internal Revenue Code Sections:
• General Testing under Section 401(a)(4)
• Average Deferral Percentage under Section 401(k)
• Average Contribution Percentage under Section 401(m)
• Deferral Limits under Section 402(g)
• Contribution Limits under Section 415
• Compensation Testing under Section 414(s)
• Compensation Limits under Section 401(a)(17)
• Coverage Test under Section 410(b)
• Benefits, Rights and Features Availability under Section 401(a)(4)
• Filing of governmental forms, including:
• Annual Return/Reporting Form 5500
• Application for Extension of Time Form 5558
• Return of Excise Tax Form 5330
• Application for Determination on Terminating Plan Form 5310
• PBGC Premiums Filing
• EPCRS error corrections under SCP and VCP
• Section 409A Corrections and Statements (corporate and individual)
• Plan amendment/document reviews
• Review of Summary Plan Descriptions (SPDs), Summary of Material Modifications (SMMs) and Annual Notices
• Plan freeze, spinoff and acquisition support

OPERATIONAL AUDITS

Our typical operational audit examines day-to-day plan operations, including the activities of outsourced plan administrators and recordkeepers, against the client’s administrative, operational and regulatory requirements.

An entry-level starting point is to conduct an analysis of the “big-ticket” items that the IRS focuses on in audit situations, such as loan disbursements, minimum required distributions and the process for finding missing participants. Alternatively, a plan sponsor may ask us to examine a test population of participants who meet certain eligibility, pay or service criteria.

A comprehensive plan audit may include:

• Comparison of plan document(s) against the requirements document(s) used to program the administration system and against actual administration system configuration
• Review of administrative operations manuals and call center knowledge systems
• Analysis of data ownership and data flow from payroll to administration systems and, if applicable, conceptual review of the recordkeeper’s data integrity tool
• Review of eligibility processes and related data points, including periodic feeds of data from payroll to administration, historical stored data and dynamic age and service calculations
• Evaluation of benefit calculations and regulatory limits
• Analysis and sample validation of various distribution types as well as reductions, discontinuation and reassignment of payment amounts
• Review of administrative processes required for the financial operation of the plan(s), including check handling, lump-sum payment protocols, periodic death searches and address change management

We thoroughly document the findings of each plan compliance review or operational audit in a report that includes practical recommendations for issue resolution.

This service is available for the following benefit plan types: