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GASB 43 & 45: Other PostEmployment Benefits Greene, Finney & Horton, LLP 864-232-5204 Larry Finney, Partner October, 2008 OPEB – What is it? Payments made to former employees or their beneficiaries, or to third parties on their behalf, as compensation for services that were rendered while they were active employees. OPEB – What is it? Post-Employment Benefits Other than Pensions provided to employees Most Common Benefit: Healthcare insurance promised to retirees Other benefits, if provided separately from a pension plan (for example, life insurance, legal services or disability) OPEB – What’s the Big Deal? The State of South Carolina has an estimated $9 billion unfunded OPEB liability on top of a $9 billion unfunded pension liability South Carolina is among the majority of the states and local governments that currently account for OPEB costs on a pay-as-you-go basis; for example, the monthly premium payment to the insurance carrier for current retirees is the only cost being recognized OPEB – What’s the Big Deal? OPEB liabilities for other states and local governments are much larger than SC: California - unfunded retiree health care tab could be as high as $70 billion, costing the state $6 billion annually for the next 30 years Maryland – estimated at $20 billion Boston - $5.2 billion, costing the city $176 million annually for 30 years OPEB – What’s the Big Deal? Our experience to date is that if the benefits are not changed, moving from a pay-as-you-go basis to GASB 43/45 results in the GASB 43/45 annual required contributions being about 4-6 times the pay-as-you-go requirements, but much of this depends on the benefits being offered GASB #43 and GASB #45 – Implementation Dates Type of government for purposes of GASB #34 Phase I Governments Phase II Governments Phase III Governments GASB 43: GASB 45: Plans for FY Employer - FY beginning after: beginning after: 12/15/05 12/15/06 (FYE 6/30/07) (FYE 6/30/08) 12/15/06 (FYE 6/30/08) 12/15/07 (FYE 6/30/09) 12/15/07 (FYE 6/30/09) 12/15/08 (FYE 6/30/10) OPEB – Why were GASB #43 and GASB #45 issued? To reflect complete and reliable financial reporting regarding the costs and obligations that governments incur when they provide post-employment benefits other than pensions as part of the compensation for services rendered by their employees Pay-as-you-go accounting only reports costs after the employees retire and fails to account for promised future benefit payments as the services are being rendered Background Information Defined Contribution plan Defined Benefit plan Inputs Outputs Financed-contractually required payments Financed-pay as you go or advance funded Risk-employee Risk-plan or employer Background Information Some misconceptions GASB requires advance funding OPEB will eliminate fund balance Catching up on OPEB from previous years will result in a large liability No written agreement means no OPEB As long as retirees pay their health care premiums there is no health care OPEB As long as a contribution is made by the employer it does not matter how it is accounted for Background Information To qualify as the equivalent to a trust: Employer contributions must be irrevocable Assets must be dedicated to providing plan benefits Assets must be protected from creditors of employers and administrators So you can’t just earmark contributions Can’t reserve or designate fund balance Background Information OPEB versus Pension Benefits Post-Employment healthcare is always considered OPEB regardless of whether administered by a Pension Plan Other types of benefits (life insurance, disability, etc.) if offered through a pension plan are not considered OPEB benefits but should be accounted for as part of pension benefits GASB #45 – Funding of OPEB Funding contributions involve a 3 step process Project the future benefit payments Discount those benefit payments to present value Allocate the present value of the benefits to appropriate periods of service GASB #45 – Funding of OPEB Project the future benefit payments Usually based on employer/employee shared understanding of promises made by employer to provide benefits to employee upon retirement (“substantive plan”) GASB #45 – Funding of OPEB Discount future benefit payments to present value Estimated inflation rate between present and retirement GASB #45 – Funding of OPEB Allocate the present value of the benefits to appropriate periods of service Six accepted methods available GASB #45 – Actuarial Valuations OPEB Cost – derived from an actuarial calculation that must be done every: two years (200 or more plan participants) three years (less than 200 plan participants) Any year in which substantial changes are made to the plan Employers with less than 100 plan participants have option to use a nonactuarial approach GASB #45 – Actuarial Valuations Calculations are based on Assumptions: Turnover rate Retirement age Health care cost factors (age, gender, inflation, etc.) Mortality Projected salary increases Inflation rate Expected rate of return on plan assets Benefit design and promises to retirees GASB #45 – Actuarial Valuations Actuarial gains and losses Gains come from the actual costs being less than the actuarial calculated costs Losses come from the actual costs being more than the actuarial calculated costs GASB #45 – What is? Annual Required Contribution (ARC)? Portion of present value of cost of OPEB earned by employees for a given period Usually is the OPEB cost for accounting purposes GASB #45 – What is? Actuarial Accrued Liability (“AAL”) Present value of benefits already earned by employees based on their service Not just what is vested Not reported on the face of the financial statements GASB #45 – What is? Unfunded Actuarial Accrued Liability (“UAAL”) Difference between the actuarial accrued liability (“AAL”) over the actuarial value of plan assets (“AVA”) Not reported on the face of the financial statements BUT, this measure is important because it reflects benefits that have been earned but not yet paid for! GASB #45 – What can cause? Unfunded Actuarial Accrued Liability (“UAAL”) Actuarial gains and losses Changes in benefit formula Transitional liability for unfunded past costs prior to implementation of GASB 45 This can happen if an employer is fully funding the ARC! GASB #45 – How do we handle a UAAL? ARC is made up of: Normal Cost Portion of benefits which is allocated to that fiscal year by the Actuarial Cost Method used Amortization of the Unfunded Actuarial Accrued Liability or “UAAL” 30 year maximum period Level dollar or level percentage of payroll GASB #45 – Accounting and Financial Reporting by Employers for OPEB Expense/expenditure recognized in financial statements for defined contribution plans and cost-sharing multiple employer defined benefit plans is the total of the contractually required contributions For other plans, it is the ARC GASB #45 – Accounting and Financial Reporting by Employers for OPEB When an employer does not fully fund the ARC, a liability is created-Net OPEB Obligation Note that when the ARC is not fully funded, there will be future years where the actual funding is higher than the ARC GASB #45 – Accounting and Financial Reporting by Employers for OPEB Net OPEB Obligation Reported in full accrual-based statements Government-wide statement of net assets Proprietary fund statement of net assets Statement of fiduciary net assets Not reported in Governmental funds statements SO THE EFFECTS OF UNDERFUNDING ARE ONLY RECOGNIZED ON THE FULL ACCRUAL FINANCIAL STATEMENTS GASB #45 – Accounting and Financial Reporting by Employers for OPEB – Disclosure Requirements Plan description Employer Name of plan, ID of who administers the plan, what type of plan (i.e. single employer, multiple employer, etc.) Brief description of the types of benefits and the authority under which benefit provisions are established or may be amended Whether the OPEB plan issues stand-alone financial statements and how they may be obtained GASB #45 – Accounting and Financial Reporting by Employers for OPEB – Disclosure Requirements Funding Policy Disclose the authority under which the obligations of the plan members, employers and other contributing entities to contribute to the plan are established or may be amended Required contribution rates of plan members (amount and percent or as a percentage of payroll) Required contribution rates of employer in dollars or as a percentage of current-year covered payroll and, if applicable, legal or contractual maximum contribution rates GASB #45 – Accounting and Financial Reporting by Employers for OPEB – Disclosure Requirements Sole or Agent Employers should also disclose the following for each plan: For the last three years – provide the OPEB cost (and its components), contributions made (and percentages), and the net OPEB obligation (if any) Information on the funded status of the plan. Disclose the authority under which the obligations of the plan members, employers and other contributing entities to contribute to the plan are established or may be amended Disclosure of the actuarial methods and assumptions used GASB #45 – Accounting and Financial Reporting by Employers for OPEB Assets held in trust or equivalent arrangements should be maintained in a OPEB Trust Fund (similar to a Pension Trust Fund) Assets of multiple-employer plans not held in trust or equivalent arrangements should be maintained in an Agency Fund Assets of single employer plan not held in trust or equivalent arrangements does not qualify as an OPEB plan – would be deemed unfunded (designations or reservations of fund balance for example) GASB #45 – Key indicators of the financial health of a defined benefit plan Funding progress-assets compared to obligations Employer contribution trends compared to ARC UAAL as a percentage of covered payroll SO WHAT? Get going if you have not done anything! Actuarial valuation to see current status Educate Board/Council and management SO WHAT? If current status not good Evaluate options Keep current plan and find resources to fund ARC Change plan-numerous options Takes time to do this-can’t wait until the last minute