Employee Benefit Plan Audit Peer Reviews
FOR LIVE PROGRAM ONLY Employee Benefit Plan Audit Peer Reviews THURSDAY, DECEMBER 6, 2018, 1:00-2:50 pm Eastern IMPORTANT INFORMATION FOR THE LIVE PROGRAM This program is approved for 2 CPE credit hours. To earn credit you must: Participate in the program on your own computer connection (no sharing) – if you need to register additional people, please call customer service at 1-800-926-7926 ext.1 (or 404-881-1141 ext. 1). Strafford accepts American Express, Visa, MasterCard, Discover. Listen on-line via your computer speakers. Respond to five prompts during the program plus a single verification code. To earn full credit, you must remain connected for the entire program. WHO TO CONTACT DURING THE LIVE EVENT For Additional Registrations: -Call Strafford Customer Service 1-800-926-7926 x1 (or 404-881-1141 x1) For Assistance During the Live Program: -On the web, use the chat box at the bottom left of the screen If you get disconnected during the program, you can simply log in using your original instructions and PIN.
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Employee Benefit Plan Audit Peer Reviews Dec. 6, 2018 Lauren Hayes, Senior Manager Susan J. Peirce, CPA, MTax, Principal Montgomery Coscia Greilich, Plano, Texas Apple Growth Partners, Akron, Ohio lauren.hayes@mcggroup.com speirce@applegrowth.com
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Peer Review continues to be impacted by DOL initiatives EBSA Audit Quality Initiatives Reporting Compliance Initiatives DOL Resources AICPA Response and Resources
EBSA’s audit quality findings Firms auditing 200 plans 45 firms perform 37% of the audits covering 69% of plan assets Firms auditing between 100 and 200 plans 59 firms perform 10% of audits covering 11% of plan assets Firms auditing 100 plans 5,721 firms audit 53% of audits covering 20% of plan assets From Marcus Aron presentation – AICPA EBP conference May 2018 6
EBSA activities Cycle of inspections for all firms auditing 100 plans Engagement reviews of smaller firm practices From Marcus Aron presentation – AICPA EBP conference May 2018 7
EBSA’s findings Overall error rate of 40% isn’t the complete picture Large variability – size of EBP practice is a factor Large firms are not immune from problems They also dabble Their size creates different risks and problems Peer review is not a good indicator of a quality benefit plan auditor From Marcus Aron presentation – AICPA EBP Conference May 2018 8
Other Meaningful Quality Factors based on the EBSA findings Peer Review is not a useful identifier of quality work In 4 of 6 strata, audits with 5 GAAS deficiencies were performed by firms with clean peer review reports. 9
EBSA’s list of best practices Commitment to EBP work from top down An EBP audit pedigree as well as audit pedigree within the firm EBP specific training and affiliation Educate and empower staff EBP specialists Robust internal inspection program Knowing who you are and when to say “no” Stress consistency throughout EBP practice 10
AICPA Peer Review Response After the 2014 DOL report was released, AICPA analyzed results of 109 Enhanced Oversight reviews of EBPs Determined that the DOL audit quality study was similar to the enhanced oversight findings Identified common areas of non-conformity Detected misconceptions driving non-conformity 11
Enhanced oversight of EBPs 2015-2016 19% Conforming engagements 50% 31% 12 Non-conforming engagements not identified by reviewers Non-conforming engagements identified by reviewers
AICPA enhanced oversight objectives Objectives Focus on must-select engagements 13 Identify material departures from professional standards Evaluate the performance of peer reviewers Provide education and feedback to peer reviewers and firms
AICPA EBPAQC Resources Plan Advisories EAlerts Webinars Primers Website Tools Resource Centers 14 Member-tomember Forum
AICPA EBPAQC Planning Tool Shared with permission of EBPAQC 15
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AICPA response – Competency certificates Early April 2016, the AICPA launched an employee benefit plan certificate program to allow practitioners to show their competency. 17
AICPA response – Competency certificates 18
AICPA response – Competency framework Creation of competency framework for employee benefit plans will help practitioners assess whether they have the competency needed for employee benefit plan financial audits and, if not, what curriculum they need to gain competency. 19
Peer Review is Evolving Each Year 21
Enhanced Oversight “ A sound audit does not occur by chance.” Susan S. Coffey, CPA, AICPA executive vice president “When the enhanced oversight program first started, the focus was on detecting quality challenges, but the primary focus has evolved to determining the characteristics of the firms we find are performing well, as well as digging deeper to discover why firms with performance issues are not performing well.” Jim Brackens, CPA AICPA vice president of ethics and practice quality. 22
Specific focus on reforms to enhance quality and accountability 2014 piloted an enhanced oversight program in which subject-matter experts conducted surprise examinations of a sample of engagements after the completion of peer review 2015 program was expanded 2016 pilot program was converted to a permanent part of the Peer Review Program and root cause analysis was introduced 23
Increased focus 2015 and 2016 peer reviews included increased focus on specialized industries Includes employee benefit plans Specialized industries Areas where peer reviewers and expert noted the greatest issues 2017 peer reviews had greater expertise oversight and subject matter expert reviewers performed enhanced assessment of firms’ quality control systems 24
2018 – A Significant Difference October 2018 Peer Review Alert included clarifications of the September 2018 Peer Alert dealing with Risk Assessment Critical to read and review your firm’s policies New Guidance on the Evaluation of Noncompliance with Risk Assessment Standards and its Impact to the Peer Review (PRPM Section 3100, Supplemental Guidance) 25
Use of PPC checklists Peer Review Board expressed concern with the proper assessment of risk and linking that assessment to audit procedures. Special Report was issued in September 2018 PPC Accounting & Auditing Update Sept 2018: 26
Quality trends based on the Enhanced Oversight Analysis indicates the most common cause of material non-conformity in audits is a lack of adequate audit documentation Inadequate documentation is cause of 50% of non- conformity 2019 peer reviews will have increased emphasis on audit documentation with focus on risk assessment 27
Reporting Requirements GAAP financial statements are required Additional regulatory requirements DOL reporting requirements IRS reporting requirements Peer reviews require adherence to ALL of the above requirements 28
Reporting Guidance Related to Peer Review AICPA Revised Interpretation 63-1 Consideration for selection: A. Reasonable cross-section of the reviewed firm’s accounting and auditing practice B. Emphasis on higher-risk practice areas 1. Risk of engagements and types of benefit plans as part of the selection criteria 2. Limited vs. full scope 3. Types of plans (DC, DB, H&W and 403(b) plans) C. Firm’s length of experience and number of audits performed, member’s experience and CPE/specialized training 29
Understanding the Unique Reporting Requirements of Employee Benefit Plans Users of financial statements Participants Plan Sponsor DOL IRS State Insurance Departments 30
Unique risks associated with different types of ERISA plans Defined contribution – Participant account and allocation testing and timely remittance of participant contributions. Defined benefit – Actuarial present value of accumulated plan benefits and changes in actuarial present value of accumulated plan benefits. Health & welfare – Benefit obligations and changes in benefit obligations. Employee stock ownership plans – Annual appraisal of securities and leveraged ESOPs Peer reviewer must consider the unique risks and document how these risks were addressed. 31
What is the Peer Review Requirement Licensed firms are required to have peer review Report acceptance body is either: State peer review committee AICPA Peer Review Board’s National Peer Review SEC registrant’s plans are not subject to peer review Engagements subject to GAAS, SSARA,SSAE, GAGAS and non-SEC issuers are subject to peer review 32
Impact of not enrolling or omission Firms that are not enrolled in the program as required by AICPA membership bylaws or their state regulatory authority will be referred to AICPA Professional Ethics Division or the appropriate regulatory or licensing authority. Firms that omit an EBP audit from the scope of their peer review will be notified that their most recent peer review acceptance letter will be recalled. The firm will be subjected to a hearing panel 33
Peer Review deadline Peer review is due every 3rd year, six months after the firm’s fiscal year end This impacts plans that are reviewed 34
Preparing for a Peer Review Every audit must meet your firm’s QC standards Be prepared Track general data on the number, size and type of employee benefit plan audits Peer reviewers must select engagements that are considered to have added “risk” full-scope audits 403(b) ESOPs Health and welfare initial engagements 35
Preparing for a Peer Review (cont.) Interviews with Firm Personnel EBP team members need to use EBP “language” Training should start with the 1st plan audit EBP team members need more than checklist mentality EBP team needs specialized training Make certain that you are in compliance with your own firm policies Review results of prior peer review Workpaper lockdown Internal inspection Use AICPA checklist for inspection 36
Preparing for a Peer Review (cont.) Peer Review Checklists AICPA Peer Review Program Manual PRP §20,700 (dated September 2018) Employee Benefit Plan Audit Engagement Checklist: 37
Preparing for a Peer Review (cont.) 2018 Employee Benefit Plans Must-Select FAQs: 38
Preparing for a Peer Review (cont.) -assessment-resources.html 39
Preparing for a Peer Review (cont.) Preparation for your next peer review starts as soon as the current review is completed Correct findings immediately; avoid repeat findings Communicate findings to your team Consider using outside professionals to perform internal inspections Specialized ERISA training for your team If the outcome is poor, hire a consultant to do a more indepth review of your ERISA practice and engagements 40
Peer Review Overview Revisiting professional standards 41 Anticipating peer reviewer expectations Best practices & avoiding common auditor documentation pitfalls Overview of inspection requirements & considerations for EBPAQC members
Revisiting the Professional Standards AU-C Section 230, Audit Documentation 42 Audit documentation required to contain evidence of the following: Auditor’s basis for conclusions about achievement of overall objectives of the auditor Audit was planned and performed in accordance with GAAS, and applicable legal & regulatory requirements
Revisiting the Professional Standards AU-C Section 230, Audit Documentation 43 Several purposes served by audit documentation For engagement team: Assist in planning & performing the audit Demonstrate accountability for work performed, evidence examined & conclusions reached Retain record of matters of continuing significance to future audits of same entity
Revisiting the Professional Standards AU-C Section 230, Audit Documentation 44 Necessary for execution of various inspections and reviews Quality control reviews & inspections in accordance with QC Section 10, A Firm’s System of Quality Control (SQCS No. 8) External inspections or peer reviews in accordance with applicable legal, regulatory or other requirements Subsequent year audit team members & predecessor auditor reviews
Revisiting the Professional Standards AU-C Section 230, Audit Documentation 45 Form, Content & Extent Experienced auditor, with no prior connection to the audit, should be able to understand: Nature, timing & extent of procedures performed Results of audit procedures performed & evidence obtained Significant findings & issues Conclusions reached Significant judgments made in reaching those conclusions
Revisiting the Professional Standards AU-C Section 230, Audit Documentation 46 A closer look at supporting nature, timing & extent of procedures performed to identify: Characteristics of specific items or matters tested Abstracts or copies of significant contracts or agreements inspected Who performed the work and date completed Who reviewed the work performed, date and extent of such review
Revisiting the Professional Standards AU-C Section 230, Audit Documentation 47 Document justification for any departures from presumptively mandatory requirements Support sufficiency of alternative procedures performed Document circumstances encountered that led to additional procedures after audit report date Procedures, evidence & conclusions Resulting changes – by whom & date prepared and reviewed
Revisiting the Professional Standards AU-C Section 230, Audit Documentation 48 Final audit file Document audit report release date Assemble final documentation & complete administrative process of assembling final audit file on timely basis (“documentation completion date”) No later than 60 days following audit report release date
Anticipating Peer Review Audit Documentation Expectations Written Audit Programs and avoiding “One Size Fits All” Mentality 49 Type of Plan Defined benefit or defined contribution pension Health and welfare benefit plans Engagement Scope Full scope Special considerations for plans subject to SEC filing Limited scope audit exemption
Anticipating Peer Review Audit Documentation Expectations Firm’s System of Quality Controls in Accordance with Statement on Quality Control Standard No. 8 Ensure Engagement Quality Complies with Professional Standards 50 Engagement quality control reviews Internal inspection program CPE and related compliance Independence (AICPA, DOL, SEC/PCAOB, etc.) Client acceptance & reacceptance
Anticipating Peer Review Audit Documentation Expectations Firm’s System of Quality Controls in Accordance with Statement on Quality Control Standard No. 8 Measurement of Compliance with Professional Standards 51 Inspection results Maintenance of CPE compliance tracking mechanisms Policy for & results of review of certain documents by individual outside of engagement team
Presenter’s Bio Susan J. Peirce, CPA, MTax Sue Peirce is a principal and leads the employee benefits audit and specialty services team at Apple Growth Partners. Sue has led the development of numerous services at the firm including specialty audit services, benefit plan design and administration, and SOC engagements. She has implemented Lean principles in the delivery of audit services to achieve more efficient processes and outcomes in audit engagements. Sue regularly writes articles, hosts webinars, and has presented at numerous events including the AICPA National Employee Benefit Plan Conference, Matrix Financial Solutions Annual Conference, and various state CPA societies. In addition to her audit work, she provides consulting services to business owners and professionals with a special emphasis on benefit plan services. Her expertise includes a focus on qualified retirement plans and related design, compliance, nondiscrimination testing, distribution and reporting issues. Sue is a former member of the AICPA Employee Benefit Plan Audit Quality Center Executive Committee. 52
Common Plan Audit Deficiencies EBPAQC Membership Peer Review Process/Best Practice 2018 Montgomery Coscia Greilich LLP 53
COMMON PLAN AUDIT DEFICIENCIES 2018 Montgomery Coscia Greilich LLP 54
High Risk Engagements ESOPs: Over 50% of plans subject to DOL inspection contained deficiencies Failure to identify valuation of employer stock in the risk assessment Review of the work of the appraiser (full-scope audits) Testing releases of shares and purchases of shares H&W Plans Can be extremely complicated with various benefits included under the plan Audit of the trust versus the plan Multi-Employer Plans 2018 Montgomery Coscia Greilich LLP 55
Most Common Audit Issues SOC analysis deficiencies Investment testing deficiencies Participant data testing deficiencies Documentation issues Non attest services 2018 Montgomery Coscia Greilich LLP 56
Service Auditor Reports Was a type 1 or type 2 SOC 1 report used as audit evidence to support the Firm’s understanding about the design and implementation of controls? If a type 2 is reducing procedures, was it properly evaluated? EBPAQC has a tool for documenting consideration of SOC reports 2018 Montgomery Coscia Greilich LLP 57
Risk Assessment Recent AICPA Requirements: Peer reviewers have been instructed to identify an engagement as “not performed” in accordance with professional standards if the peer reviewer identifies non-compliance with the Risk Assessment Standards covered in AU-C sections 315 and 330 Risk assessment documentation findings should be included in the oversight report as findings that result in a non-conforming engagement Effective for peer reviews commencing on or after October 1, 2018 2018 Montgomery Coscia Greilich LLP 58
Risk Assessment Failure to gain an understanding of internal control when identifying client’s risks: Auditors are expected to perform the following steps when gaining an understanding of internal control; an audit omitting one or more of these steps results in non-compliance Consider what could go wrong as the client prepares its financial statements Identify the controls intended to mitigate those financial reporting risks Evaluate the likelihood that the controls are capable of effectively preventing or detecting and correcting material misstatements. Some auditors may indicate that the requirements of AU-C 315.14 do not apply to their client because their client has no controls. This is a false assumption. Auditors may default to control risk at the maximum level without gaining an understanding of the client’s internal control. This is not permitted under the current Risk Assessment Standards, even when not intending to rely on tests of controls. Auditors may reduce control risk to less than high without appropriately testing relevant controls. 2018 Montgomery Coscia Greilich LLP 59
Risk Assessment Insufficient risk assessment: Regardless of the nature and extent of substantive procedures, performing the audit in accordance with GAAS includes the following requirements for each engagement; omitting one or more of these requirements results in non-compliance Identify the client’s risks of material misstatement (RMM) by gaining an understanding of the client and its internal control (Identify RMM) Assess the risks (Assess RMM) and Design or select procedures that respond to those risks (Respond to RMM) Failure to identify at least one significant risk almost always represents a failure to comply with AU-C 315.28 Failure to assess risk of material misstatement at both the financial statement level and relevant assertion-level for significant classes of transactions, account balances or disclosures represents non-compliance with AU-C 315.26 Some auditors are documenting RMM at the audit area level for every audit area, citing the risk assessment is the same for all assertions, when not all assertions are relevant 2018 Montgomery Coscia Greilich LLP 60
Risk Assessment Failure to link procedures performed to the risk assessment: Audit procedures should be responsive to the client’s financial statementand relevant assertion-level risks for significant classes of transactions, account balances or disclosures. The linkage is at the assertion (not account) level. Some auditors are performing the risk assessment in accordance with AU-C 315 but designing the audit procedures with little regard for the results of that assessment. If the risks are not properly reduced to an acceptably low level, the auditor hasn’t complied with the standards. 2018 Montgomery Coscia Greilich LLP 61
Participant Data/Accounts: Audit Objective To provide the auditor with a reasonable basis for concluding (a) whether all covered employees have been properly included in employee eligibility records and, if applicable, in contribution reports; and (b) whether accurate participant data for eligible employees were supplied to the plan administrator and, if appropriate, to the plan actuary 2018 Montgomery Coscia Greilich LLP 62
Participant Data/Accounts: Audit Objective No audit work performed or no audit documentation of testing participant data Testing of payroll data insufficient Risk of plan non-compliance with provisions – definition of eligible compensation (also effects contributions) No testing of participant eligibility, termination or forfeitures Risk of plan non-compliance with provisions – missed or late entry dates, entry date too early Forfeitures miscalculated, forfeitures not used in accordance with the plan No testing of investment income or investment election allocation to participants No reconciliation of participant accounts to total plan assets 2018 Montgomery Coscia Greilich LLP 63
Investments: Audit Objective Full scope audit – To provide the auditor with a reasonable basis for concluding a) whether all investments are recorded and exist; b) whether investments are owned by the plan and are free of liens, pledges, and other security interest or, if not, whether the security interests are identified; c) whether investment principal and income transactions are recorded and investments are properly valued in conformity with U.S. generally accepted accounting principles as promulgated by the Financial Accounting Standards Board (FASB) (GAAP) or a special purpose framework that is acceptable to the DOL, such as the modified cash basis of accounting; d) whether information about investments is properly presented and disclosed; and e) whether investment transactions are initiated in accordance with the established investment policies 2018 Montgomery Coscia Greilich LLP 64
Investments: Audit Objective Limited scope audit - The auditor’s responsibilities for any assets covered by the limited scope exception are a) to compare the information certified by the plan’s trustees or custodian to the financial information contained in the plan’s financial statements; b) to perform the necessary procedures to become satisfied that any received or disbursed amounts reported by the trustee or custodian were determined in accordance with the plan provisions; and c) whether information about investments is properly presented and disclosed. 2018 Montgomery Coscia Greilich LLP 65
Investments: Audit Objective Full scope audits: Failure to test investment transactions and/or income Failure to test end-of-year market values Failure to confirm existence and ownership of investments through direct confirmation procedures Limited scope audits: Failure to obtain proper certification Improper use of limited scope exemptions Failure to understand testing requirements Inadequate or missing disclosures related to investments 2018 Montgomery Coscia Greilich LLP 66
Contributions: Audit Objective To provide the auditor with a reasonable basis for concluding (a) whether the amounts received or due the plan have been determined and recorded and disclosed in the financial statements in conformity with plan documents and generally accepted accounting principles; and (b) whether an appropriate allowance has been made for uncollectible plan contributions receivable in conformity with GAAP or a special purpose framework 2018 Montgomery Coscia Greilich LLP 67
Contributions: Common Deficiencies No audit work performed or no audit documentation Insufficient testing on contributing employers for multi-employer plans Failure to test compliance with compensation provisions This is the area that most non-compliance is found in a plan - Improper definition of eligible compensation Failure to test forfeitures Timeliness of participant contributions not tested 2018 Montgomery Coscia Greilich LLP 68
Benefit Payments: Audit Objective Provide the auditor with a reasonable basis for concluding (a) whether the payments are in accordance with plan provisions and related documents; (b) whether the payments are made to or on behalf of persons entitled to them and only to such persons; and (c) whether transactions are recorded in the proper account, amount and period 2018 Montgomery Coscia Greilich LLP 69
Benefit Payments: Audit Objective No audit documentation or no audit work performed Failure to test participant eligibility to receive benefit payments Failure to test approval/validity of benefit payments Failure to test vesting 2018 Montgomery Coscia Greilich LLP 70
Documentation: Common Deficiencies Lack of documentation results in a majority of peer reviewer findings Firms are required to document: Nature, timing, and extent of procedures Results of those procedures Any significant findings, issues, or professional judgement Remember if you didn’t document the procedure, it’s considered not to have been done 2018 Montgomery Coscia Greilich LLP 71
Other Areas: Common Deficiencies No audit documentation or no audit work performed for related-party and party-in-interest transactions Failure to understand and/or test administrative expenses Inadequate planning and supervision Non-attest services not documented Reporting: Incomplete description of the plan and its provisions Failure to properly report on and/or include the required supplemental schedules relating to ERISA and DOL 2018 Montgomery Coscia Greilich LLP 72
Materiality Plan Financial Statement Level Regulatory / Participant Level 2018 Montgomery Coscia Greilich LLP 73
E B PA Q C MEMBERSHIP 2018 Montgomery Coscia Greilich LLP 75
Considerations for EBPAQC Members EBPAQC Membership Requirements Designated audit partner in charge of EBP Partners must be members of AICPA System of quality control Monitoring program with internal inspections Peer review report made public EBPs must be selected for peer review Periodically file information about EBP practice Pay dues established by executive committee 2018 Montgomery Coscia Greilich LLP 76
Considerations for EBPAQC Members Inspection Program Requirements for Internal and External Peer Reviews Review of specific engagements Review of CPE records Review of training program (if applicable) Summarize and evaluate the findings Communicate inspection results Remediate issues as needed See AICPA EBPAQC tool on Web site 2018 Montgomery Coscia Greilich LLP 77
PEER REVIEW PROCESS 2018 Montgomery Coscia Greilich LLP 78
Peer Review Process Peer reviewers look at the firm as a whole and perform “risk assessment.” Understand the firm Commitment to the employee benefit plan practice Understand where the EBP practice fits in the overall firm’s practice Approach to maintaining quality to employee benefit plans 2018 Montgomery Coscia Greilich LLP 79
Peer Review Process Gain an understanding of the firm and assesses risk Select engagements Review engagements - AICPA EBP audit engagement checklist Report and related disclosures General audit procedures Working paper areas Engagement team responds and clarifies any “No” answers. 2018 Montgomery Coscia Greilich LLP 80
Peer Review Process Types of Findings Types of Observations Matters Most minor issues related to documentation, and no material misstatement Communicated on matters for further consideration (“MFC”) Still a good audit with “pass” rating Findings One or more matters that suggest quality control issues Documented on a findings for further consideration (“FFC”) form If conclusion is not a deficiency or significant deficiency, a “pass” ratin
Employee Benefit Plan Audit Peer Reviews Lauren Hayes, Senior Manager Montgomery Coscia Greilich, Plano, Texas lauren.hayes@mcggroup.com . Employee Benefit Plan Audit Engagement Checklist: Preparing for a Peer Review (cont.) 38 2018 Employee Benefit Plans Must-Select FAQs:
DNR Peer A Peer B Peer C Peer D Peer E Peer F Peer G Peer H Peer I Peer J Peer K 14 Highest Operating Margin in the Peer Group (1) (1) Data derived from SEC filings, three months ended 6/30/13 and includes DNR, CLR, CXO, FST, NBL, NFX, PXD, RRC, SD SM, RRC, XEC. Calculated as
CPA firms that were members of the American Institute of Certified Public Accountants' (AICPA) Employee Benefit Plan Audit Quality Center tended to produce audits that have fewer audit deficiencies. Overwhelmingly, most CPAs in the two smallest audit strata are not Employee Benefit Plan Audit Quality Center members.
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The quality audit system is mainly classified in three different categories: i Internal Audit ii. External Audits iii. Regulatory Audit . Types Of Quality Audit. In food industries all three audit system may be used to carry out 1. Product manufacturing audit 2. Plant sanitation/GMP audit 3. Product Quality audit 4. HACCP audit
disclosures, see Employee Benefits Law § 10.03, paragraph [4]. Also see AICPA, Employee benefit plans — financial statement audits. General Form 5500 Filing Information Form 5500 is the annual financial report for all ERISA employee benefit plans (employee pension benefit plans and welfare benefit plans alike). ERISA § 102(a)(1)(A) (29 U.S .
INTERNAL AUDIT Example –Internal audit report [Short Client Name] Internal Audit Report Rev. [Rev Number] STEP ONE: Audit Plan Process to Audit (Audit Scope): Audit Date(s): Lead Auditor: Audit #: Auditor(s): Site(s) to Audit: Applicable Clauses of [ISO 9001 or AS9100] S
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