EB plan audits increasing

ALERT: Department of Labor increasing employee benefit plan audits; urges plan sponsors to choose external audit firms carefully.

April 4, 2016

The Department of Labor appears to be sending plan sponsors two parallel messages based on its hiring trends and a 2015 DOL study of employee benefit plan audit quality.

The Department of Labor appears to be sending employers two parallel messages based on its hiring trends and a 2015 DOL study of employee benefit plan audit quality. Both messages are critical to help plan sponsors avoid potentially significant penalties for noncompliance.

Increase in DOL audits

An increase in DOL auditors means a likely increase in ERISA audits for plan sponsors – so even if you haven’t faced a DOL audit, your chances of doing so are now higher. Now is the time to make sure your retirement plan is in order and can sustain a rigorous DOL review.

While an IRS audit may be more feared, DOL audits can result in serious fines and penalties for plan sponsors found to be non-compliant with ERISA law. A more aggressive DOL approach to auditing and enforcement means plan sponsors should carefully review all aspects of their retirement plan and be ready to respond to DOL inquiries with a current plan document, summary plan description (SPD), documentation of compliance with the plan’s document, participant notices, fee disclosures, investment monitoring and prudence, and a process to ensure ERISA regulations are followed.

Employee benefit plan audit firm selection

The DOL’s own study of CPA firms auditing employee benefit plans found a link between the quality of the audit and the number of employee benefit plans the CPA firm audited. The larger the firm’s employee benefit audit practice, generally the fewer audit deficiencies found. The DOL’s 2015 study shows that 93% of the CPA firms surveyed conducted fewer than 24 plan audits per year. Per the study, “There is a clear link between the number of employee benefit plan audits performed by a CPA and the quality of the audit work performed.”

DOL findings suggest that when choosing an employee benefit plan audit firm, plan sponsors should ask about the firm's:

  • Number of plans audited
  • Training specifically for employee benefit plan auditing
  • Membership in the American Institute of Certified Public Accountants (AICPA) Employee Benefit Plan Audit Quality Center

What if I have questions?

For more information about DOL audits or choosing an employee benefit plan audit firm, please contact AGH assurance vice president Aron Dunn, who heads the firm’s employee benefit plan audit practice, or AGH senior vice president of employee benefit services Brad Bechtel using their information below.

Aron Dunn

Chief Executive

Aron Dunn assumed the role of Chief Executive in 2026. He has been part of AGH CPAs & Advisors for 30 years, beginning as an intern and growing into a nationally respected leader in assurance services and in the accounting profession at large. His deep technical expertise, strong character and clear commitment to serving clients make him exceptionally well suited to guide AGH into its next chapter.

Aron has built a distinguished career serving clients in the construction, contracting and agribusiness industries, among other business sectors. In addition, he has special-project background in mergers and acquisitions and refinancing.

His leadership extends nationally through the American Institute of Certified Public Accountants (AICPA), the Construction Financial Management Association (CFMA), and the Kansas Society of CPAs (KSCPA), where he served as the youngest-ever chair.

Aron also brings a strong commitment to community engagement through his work with the Greater Wichita YMCA, United Way of the Plains, and the Greater Wichita Chamber of Commerce.

Brad Bechtel

Senior Vice President
Employee Benefit Services

Brad Bechtel leads AGH’s employee benefit services (EBS) division, which serves clients nationwide. EBS is one of the region's largest providers of retirement plan recordkeeping services for daily valuation plans. The division provides consulting services to clients on employee benefit plans, including plan design, implementation, operation, fiduciary due diligence, compliance, and through affiliate AGH Wealth Management, discretionary and non-discretionary investment fiduciary services, investment advisory services and employee education.

Brad is experienced in executive compensation, including non-qualified, phantom stock, top hat and excess benefit plans, as well as other deferred compensation approaches. He has consulted for numerous Fortune 500 corporations on investment management and fiduciary due diligence. He also provides search and selection due diligence consulting services for companies seeking new investment and recordkeeping providers for their qualified plans. Brad is a registered investment advisor who holds Series 7, 24 and 66 FINRA registrations, and he is a member of the American Society of Pension Professionals & Actuaries.

Information in this document has been obtained by Allen, Gibbs & Houlik, L.C. from sources believed to be reliable. However, AGH does not guarantee the accuracy nor completeness of any information. This communication does not and is not intended to provide legal, accounting or other professional advice or opinions on specific facts or matters, and accordingly, AGH assumes no liability whatsoever in connection with its use. Nothing in this communication can be used to avoid penalties that may be imposed by a governmental taxing authority or agency.

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