Did you know that employee benefit plans audit was mandatory for plans with 100 eligible participants or more until 2023? The Department of Labor changed this requirement. Plans now need audits only if they have 100 participants or more with account balances at the start of the plan year.
The DOL made this change to match costs with benefits. This reduced the number of plans needing audits and made things easier for smaller plans. The AICPA pointed out that most audit failures happen because auditors lack training and experience with employee benefit plan audits.
ERISA audits must be done right. These audits check if your plan can cover current and future benefits and payments to protect its financial health. Most calendar year plans must file Form 5500 by July 31 of the following year, which is seven months after the plan year ends.
Let us show you the basics of outsourcing EBP audits. We created a complete blueprint to help you direct benefit plan audits in 2025 and beyond. You’ll learn everything from the right time to outsource to picking the best audit firm and handling the process afterward.
Understand When and Why to Outsource an EBP Audit
Employee benefit plan audits can be complex and time-consuming processes that need specialized knowledge and resources. Organizations must decide whether to handle these audits in-house or outsource them as this choice impacts their business.
The right time to outsource
The Department of Labor now focuses more on audit quality and targets firms that perform five or fewer employee benefit plan audits. This increased scrutiny makes outsourcing a necessity for organizations that lack EBP audit experience.
You should consider outsourcing if:
- Your plan exceeds the participant threshold that requires an audit (generally more than 100 participants with balances as of the first day of the plan year)
- Your team lacks specialized EBP audit knowledge
- Your internal resources get stretched during busy seasons
- You need help staying current with ERISA regulations
- You want to avoid non-compliance penalties (failing to meet ERISA audit standards can lead to serious consequences)
CPA firms often perform employee benefit plan audits to protect their client relationships, even though they don’t specialize in this area. These firms can maintain client satisfaction and reduce regulatory risks by outsourcing to specialists.
Benefits of outsourcing vs. in-house audits
Outsourcing EBP audits has several advantages compared to internal handling. Specialized audit firms bring expertise and objectivity to your process. External auditors work independently from your organization, which ensures better objectivity and reduces potential conflicts of interest.
Outsourcing helps you save money. Running an in-house audit team costs more in salaries, training, and infrastructure, while outsourcing lets you pay only for services you need.
Your organization gets flexibility and scalability that in-house teams struggle to provide. External audit firms adapt quickly to your changing needs, whether you need more audit work or specific expertise.
Your staff can focus on core competencies and strategic initiatives instead of compliance tasks. This shift in resources improves your organization’s efficiency and your team’s satisfaction.
Prepare Your Plan for a Smooth Audit Handoff
Getting ready before an audit starts can save time, reduce stress, and lead to better results. Taking action early will give you a smoother process with fewer issues along the way.
Gather key plan documents and data
Employee benefit plan audits rely on quality documentation that’s easy to access. Plan administrators should start collecting these vital materials ahead of time:
- Plan document and amendments (including Summary Plan Description)
- Financial statements and trust schedules
- Payroll records and annual census data
- Participant records (enrollment forms, contribution elections, distributions)
- Fidelity bond coverage documentation
- Minutes from meetings related to the plan
The “auditor’s package” from your service provider should be requested as early as possible. This complete package shows reports of your plan’s operations throughout the year. Your audit team should receive this package right away to help them plan better.
Assign internal point of contact
One dedicated contact person should handle the entire audit process to improve communication and accountability. This person should:
- Work with third-party administrators and service providers
- Set up read-only access to online records for auditors where possible
- Handle information requests from various departments
- Be available at scheduled times to answer questions
This person bridges the gap between auditors and your organization, which speeds up the audit timeline and reduces confusion.
Ensure compliance with ERISA audit requirements
The plan must meet all Employee Retirement Income Security Act (ERISA) requirements before the audit begins. Plan administrators need written documentation that confirms their responsibility to:
- Administer the employee benefit plan
- Keep plan documents current
- Maintain accurate records of plan activities and participants
- Verify that financial statement transactions follow plan provisions
Plan administrators must also give auditors a draft Form 5500 before the final report date. This lets auditors check for any major inconsistencies or misstatements before submission.
Note that good communication, detailed record keeping, and proper record retention are the foundations of planning your employee benefit plan audit.
How to Choose the Right Audit Firm
Choosing an auditor for your employee benefit plan requires careful thought. The Department of Labor reports that 39% of employee benefit plan audits had major deficiencies. This statistic shows why making the right choice matters.
Check CPA licensing and ERISA experience
Your potential auditor must have a certified public accountant license from your state’s regulatory authority. DOL studies show a direct link between audit quality and experience. Firms that handle fewer than three ERISA plan audits yearly had a 76% deficiency rate. The deficiency rate dropped to 12% for firms managing more than 100 plan audits.
The best firms belong to the AICPA Employee Benefit Plan Audit Quality Center (EBPAQC). These firms choose to follow stricter standards and quality requirements.
Ask the right questions during evaluation
Your conversations with potential auditors should cover:
- Their yearly count of employee benefit plan audits
- Direct experience with your plan type (401k, 403b, etc.)
- Team training in EBP specialization
- Results from DOL, IRS, or peer reviews
- Quality control systems for EBP audits
Review peer reviews and audit quality history
CPA firms undergo peer review – a crucial process where other accounting professionals review their work. Ask for the firm’s latest peer review report. EBPAQC members make these reports public. You should also ask if their employee benefit plan audits were part of their peer review selection.
Understand pricing models and engagement terms
The cheapest option isn’t always the best choice. Low fees might lead to poor service and possible DOL penalties. Quality firms stand out through their experience, training, service standards, and fair pricing.
The audit contract needs a full review before work starts. This document should detail the scope, timeline, fees, and each party’s duties.
Manage the Audit Process After Outsourcing
Your role moves from evaluator to making the process easier after selecting your audit firm. The audit process needs your active participation throughout the engagement, even with outsourcing.
Set expectations and timelines
Schedule a planning meeting with your auditor before fieldwork starts. The original discussion should address:
- Preferred communication methods and frequency
- Key deadlines and audit testing schedule
- Documentation submission timelines
- Recent plan changes that might affect the audit
SAS 136 mandates plan sponsors to provide written acknowledgments before the audit begins. These acknowledgments confirm your compliance with ERISA requirements, maintenance of current plan documents, and proper financial statement preparation. Both sides need clear responsibilities established through these early commitments.
“Nothing derails a schedule more than finding out late in the engagement that a third party failed to provide required documentation,” cautions experts in the field. A detailed timeline with checkpoints helps track progress throughout the engagement.
Coordinate with third-party administrators
Your TPAs hold much of the documentation auditors need, making their coordination significant. These best practices help streamline the process:
- Grant auditors direct portal access to third-party administrator systems whenever possible
- Alert your TPA about the audit timeline ahead of time
- Include TPAs in investment discussions to reduce back-and-forth communications
Auditors meet with personnel responsible for the plan during fieldwork to understand internal controls, accounting processes, and risks – either on-site or remotely. They review samples of distributions, loans, and employee records, so prepare to help with this sampling process quickly.
Review draft reports and Form 5500 attachments
The audit’s conclusion brings draft financial statements, the auditor’s report, and notes about any internal control weaknesses discovered during review. The auditor must also review your draft Form 5500 before finalizing their report.
Your auditor provides the finalized report and audited financial statements after approval to attach to Form 5500 for DOL submission. Note that your Form 5500 filing deadline comes seven months after the plan year ends, with a possible 2.5-month extension if needed.
Conclusion
Organizations make a strategic choice when they outsource employee benefit plan audits due to complex compliance needs. This piece explores everything in effective EBP audit outsourcing. It covers regulatory changes and audit process management after you involve an external firm.
The Department of Labor has altered the map of employee benefit plan audits. Plans with 100 or more participants who have account balances at the start of the plan year now just need audits. This radical alteration highlights specialized knowledge requirements that many organizations can’t maintain internally.
Picking the right audit partner becomes the most crucial decision you’ll make. Firms with deep ERISA experience, proper licensing, and memberships in quality centers like the AICPA EBPAQC deliver exceptional results. The numbers tell the story – inexperienced auditors have a 76% deficiency rate compared to specialists at just 12%.
Success depends heavily on preparation. Your outcomes will improve dramatically when you gather detailed documentation, assign dedicated internal contacts, and ensure ERISA compliance before starting the audit. This approach reduces stress and disruption.
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Audit management requires ongoing attention even after outsourcing. Your compliance efforts stay protected when you set clear expectations, coordinate with third-party administrators, and really review draft reports before submission.
Organizations that handle EBP audits strategically will minimize risks while maximizing their employee benefit plans’ value as we look toward 2025 and beyond. Understanding outsourcing timing, preparation methods, and trusted partners creates audit excellence. The blueprint we’ve shared offers a clear path to regulatory compliance and audit success.
FAQs
Q1. When should a company consider outsourcing their employee benefit plan audit? A company should consider outsourcing their employee benefit plan audit when they have more than 100 participants with account balances at the start of the plan year, lack specialized EBP audit knowledge internally, or are concerned about keeping up with changing ERISA regulations.
Q2. What are the key documents needed for an employee benefit plan audit? Essential documents for an EBP audit include the plan document and amendments, financial statements, payroll records, participant records, fidelity bond coverage documentation, and minutes from plan-related meetings. It’s also crucial to obtain the “auditor’s package” from your service provider.
Q3. How can a company ensure they choose the right audit firm for their employee benefit plan? To choose the right audit firm, verify their CPA licensing, check their ERISA experience, ask about their EBP audit volume and specific plan type experience, review their peer review reports, and understand their pricing model. It’s advisable to select firms that are members of the AICPA Employee Benefit Plan Audit Quality Center.
Q4. What role does the company play after outsourcing the audit process? After outsourcing, the company should set clear expectations and timelines, coordinate with third-party administrators, facilitate document access, and review draft reports and Form 5500 attachments. Active involvement throughout the engagement is crucial for a successful audit.
Q5. What are the potential consequences of choosing an inexperienced auditor for an employee benefit plan audit? Choosing an inexperienced auditor can lead to major deficiencies in the audit. According to Department of Labor studies, firms performing fewer than three ERISA plan audits annually had a 76% deficiency rate, which could result in regulatory issues and potential penalties for the company.
Simplify your next employee benefit plan audit – book a free consultation today to stay compliant and stress-free.