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Statement 45 (for Employers/Sponsors). Issued June 2004Will generally affect an employer that offers retiree healthcare or other post employment benefits that are not pension benefitsIf applicable to an employer, will require accrual-basis accounting for expense and measurement and disclosure of funded status (UAAL).
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1. GASB 43 and 45Accounting for Other Postemployment Benefits (OPEBs) TAC Annual ConferenceAugust 17, 2006
2. Statement 45 (for Employers/Sponsors) Issued June 2004
Will generally affect an employer that offers retiree healthcare or other post employment benefits that are not pension benefits
If applicable to an employer, will require accrual-basis accounting for expense and measurement and disclosure of funded status (UAAL)
3. Statement 43 (for Funded Plans) Issued in April 2004
Affects administrators and sponsors of plans (here, meaning a plan that has assets)
For trusts, requires statements and disclosures similar to GASB 25; for non-trust funds, requires reporting as an agency fund
4. Executive Summary GASB Statement Nos. 43 and 45 in brief
Government employers which sponsor certain post-retirement benefits programs (e.g., medical) are affected and must generally comply with and report under GASB No. 45
Results in recording expense and liabilities in financial statements rather than typical past practice of “pay as you go” expensing
May have significant impact on sponsor’s financial statements
Funded OPEB plans must generally comply with and report under GASB No. 43
Sponsors and funded plans will need actuarial and accounting analysis to evaluate impact on accounting treatment of these plans
There is opportunity to understand implications and explore alternatives before effective date of Statements
5. What is an “OPEB”? Postemployment benefits other than pensions (“OPEB”):
Includes postemployment healthcare benefits (medical, dental, etc.)
Includes other types of non-pension benefits (e.g., life insurance) if provided separately from a pension plan (otherwise accounted for as part of pension benefits)
OPEB does not include special termination benefits, early retirement incentive programs, etc. (however, effects of these special benefits on existing OPEB plans should be accounted for under GASB Nos. 43 and 45)
OPEB does not include conversion of sick leave to individual defined contribution retiree healthcare accounts (but any subsidy in amounts charged for healthcare coverage and deducted from account are covered by GASB 43 and 45)
6. Current Practice Very few governmental OPEB plans have ever had an actuarial valuation
Most OPEB plans are financed on a pay-as-you-go basis
Financial reporting practice has generally focused on reporting outflows of current financial resources (i.e., the pay-as-you-go or cash basis)
Therefore, current financial reporting generally fails to:
Recognize the cost of benefits in periods when services are received
Provide information about the current value of future promised benefits and associated liabilities
Provide information useful in assessing potential demands on future cash flows
7. Accrual Recognition of OPEB The new standards require that OPEB costs generally be recognized over the working lifetime of employees
The new standards are the GASB-equivalent of FASB’s SFAS No. 106 in the private sector
The entity legally responsible for making the contributions should report and comply with GASB 45
Postemployment benefits (both pensions and OPEBs) are considered part of compensation for services rendered by employees, so theoretically should be expensed and accrued during the employee’s working lifetime
GASB 45 does not apply to sponsor if retirees and beneficiaries pay 100% of actuarially determined cost of coverage, taking into account only retirees and their beneficiaries
8. Implementation Provisions for GASB 45 Prospective implementation; the initial Net OPEB Obligation on balance sheet is generally set equal to $0, regardless of funded status of plan
Can develop retroactively determined Net OPEB Obligation if desired, but this will likely be very rare
Effective for periods beginning after December 15:
2006 if sponsor has >$100M revenue
2007 if sponsor has $10M – $100M in revenue
2008 if sponsor has <$10M in revenue
Earlier implementation is encouraged
9. Recognition in Governmental Entity Financial Statements Under GASB 45, financial statements of employers should recognize OPEB expense in an amount equal to Annual OPEB Cost for the period, regardless of the amount paid in cash
The cumulative difference between amounts expensed and “contributions” to the plan will create a liability (or asset) on the sponsor’s balance sheet called the Net OPEB Obligation
Additional footnote disclosure and supplementary information is required
10. GASB 43 and 45 Accounting Impact
11. Accounting for Employers The impact on the sponsor is a function of:
Type of plan (Defined Benefit vs. Defined Contribution)
Plan design
Cost sharing provisions (sponsor vs. member)
Assets in trust (if any)
Demographics of covered members
Currently virtually no government entities prefund or recognize a liability for OPEBs
12. Accounting for Employers Currently most governmental entities budget a year’s premiums/claims
In future will need to budget the ARC (plus adjustments, if any) for enterprise and internal service funds
Recognition may impact bond ratings which could change the cost of borrowing
13. Accounting for Employers Transition: employers may (not required to) calculate net OPEB obligation at transition
Most employers will set Net OPEB Obligation at transition to zero
Discussion later focuses on how the unfunded actuarial liability is factored into Annual OPEB Cost (expense) and potentially becomes a financial statement obligation
On-going Net OPEB Obligation:
Amount recognized at transition (if any), PLUS
Cumulative difference between the annual OPEB cost and the employer’s contributions
14. GASB 45 Note Disclosures (Highlights) Note disclosure requirements for OPEB employers generally are similar to those for pension employers under GASB 27
Examples:
Disclosures of plan description and funding policy (all employers)
Disclosures of amount and components of annual cost, amount actually contributed, change in Net OPEB Obligation, and % of annual cost contributed (sole and agent employers)
15. GASB 45 Note Disclosures (Highlights) However, the Board has added or modified disclosure requirements for OPEB at several points
Examples:
OPEB note disclosures include disclosure of the funded status of single-employer and agent plans in which an employer participates, as of the most recent actuarial valuation (not required for pensions under GASB 27)
16. GASB 45 Note Disclosures (Highlights) Examples (continued):
There should be expanded explanatory disclosures about actuarial methods and assumptions*
* The purpose of these is to make reported financial information about OPEB understandable to a wider range of financial report users
17. GASB 45 Note Disclosures (Highlights) Information about funded status of the plan:
Actuarial valuation date
Actuarial accrued liability (AAL)
Actuarial value of plan assets – generally a market related value
Unfunded Actuarial Accrued Liability (UAAL)
Funded ratio (actuarial value of plan assets/AAL)
Ratio of UAAL to covered payroll
Notes regarding changes affecting the interpretation of trends in the amounts reported
18. GASB 45 Required Supplementary Information (RSI):Schedule of Funding Progress Employers also will be required to disclose as RSI multi-year trend information about the UAAL and progress made in funding the plan (similar to pension plans under GASB 27), including:
Actuarial accrued liability (AAL)
Actuarial value of plan assets--generally a market related value
Unfunded actuarial accrued liability (UAAL): (AAL minus plan assets)
19. GASB 45 RSI: Required Schedule ofFunding Progress (continued)
Funded ratio (actuarial value of plan assets/AAL)
Ratio of UAAL to covered payroll (an indicator of the relative size of the UAAL)
Notes to RSI regarding changes affecting the interpretation of trends in the amounts reported
Information is required for the most recent actuarial valuation plus the two preceding valuations
Special provisions for sponsors in cost-sharing plans (information on entire plan to be included as RSI)
20. GASB 43 Financial Statements for Plans Required statements for defined benefit plans
Statement of net plan assets
Statement of changes in net plan assets
Required Supplementary Information (RSI)
This presentation is for those plans administered as trust or equivalent
Accrual basis (liabilities for benefits and refunds recognized when due)
Investments at fair value in the financial statements (but at market-related or “actuarial” value in actuarial valuations to calculate the UAAL and the ARC)
21. GASB 43 Financial Statements for Plans Note disclosures:
Plan description
Summary of significant accounting policies
Contributions/legally required reserves (includes sources and rates of contributions and funding policy)
For single and agent employers
Information about funded status as of most recent valuation date (similar to GASB 45)
General information on actuarial methods and assumptions
22. Comparison with GASB Nos. 25 and 27 as they come due. These would be plan investments for a funded plan, the employer’s investments for a pay-as-you-go plan, or a weighted average of expected plan and employer investments for a plan that is partially funded.
as they come due. These would be plan investments for a funded plan, the employer’s investments for a pay-as-you-go plan, or a weighted average of expected plan and employer investments for a plan that is partially funded.
23. Comparison with GASB Nos. 25 and 27 (cont.) as they come due. These would be plan investments for a funded plan, the employer’s investments for a pay-as-you-go plan, or a weighted average of expected plan and employer investments for a plan that is partially funded.
as they come due. These would be plan investments for a funded plan, the employer’s investments for a pay-as-you-go plan, or a weighted average of expected plan and employer investments for a plan that is partially funded.
24. Annual Required Contribution of Sponsor (“ARC”) Key measure that is basis of OPEB expense recognition, very similar to ARC for pensions under GASB 27
Represents the level of contribution effort necessary on an ongoing, sustained basis to:
Cover the normal cost for each year (normal cost is the value of the portion of the ultimate benefit allocated to the current year by cost method), and
Amortize the unfunded actuarial liability (“UAL”), or the difference between the actuarial liability and plan assets; actuarial liability is the value of future plan benefits attributable to past service of members
In calculating UAL, due and unpaid or excess contributions should not be included in assets unless settlement is expected not more than one year after the deficiency has occurred or if excess is to be used within one year
26. Actuarial Valuations Generally must perform actuarial valuation to calculate cost and obligations
Valuations will be required under GASB OPEB standards:
At least biennially for plans with 200 or more members
At least triennially for plans with fewer than 200 members
More frequent valuations are acceptable
Generally, expected that calculations would be performed by credentialed actuaries with appropriate expertise
Alternative measurement method permissible if fewer than 100 members
“Members” are current retirees or surviving spouses receiving retirement benefits plus active employees who could receive benefits in the future under current plan provisions
27. Date of Actuarial Valuation Does not need to be as of financial statement date
Must be within 24 months of first day of financial statement period if annual valuations are completed
Must be within 24 months of first day of first year of a multi-year valuation cycle if valuations are biennial or triennial
New valuation should be performed if significant changes in plan or participants covered since last valuation
28. Substantive Plan The terms of the plan as understood by the employer and participants whether written or not
Usually documented through Plan documents, SPDs, or other written communications to the participants
Pattern of actual practice and procedures
Legal or contractual caps apply for valuation purposes depending on sponsor’s record of enforcing them and other relevant facts and circumstances
Note that subsidized benefits to retirees produce OPEB obligations (e.g., if retirees were required to pay only active employee rate)
29. Implicit Rate Subsidy – An Illustration Assume a sponsor provides healthcare benefits to active employees and to eligible retirees until age 65
The sponsor pays 100% of the blended premium of $250 per month per member for active members
The retirees pay 100% of blended premium of $250 per month
Actual age adjusted premiums (approximating claims costs) are $200 for active members and $400 for retirees
By committing to allow retirees to pay only the blended premium, the employer is indirectly paying the difference between the true cost of retiree coverage and the amount being paid by the retiree by paying higher costs for the active members – this subsidy creates an OPEB obligation under GASB 45
30. Actuarial Valuation Process
31. Suggested GASB 45 Implementation Approach Perform actuarial study of current plan
Analyze funding options (could affect discount rate assumption)
Evaluate impact on financial statements, future cash flows
Consider modification of program to best meet needs of organization and employees if current plan cost is unacceptable
Actuarial study of alternative plan designs
Implementation of changes (if any)
32. Determining Cost of Current Plan (per GASB 45) Identifying affected benefits
Identifying substantive plans
Collecting data for measurement
Selecting actuarial assumptions and procedures
Measuring liabilities
33. Identifying the Substantive Plan Review plan summaries
Collective bargaining agreements
Written documents to employees
Review of actual practices
Clarify cost-sharing arrangements (with retirees)
New Medicare Prescription Drug Coverage (Part D)
Subsidy or through plan design?
Affects treatment under actuarial valuation
34. Collecting Data for Measurement Could be an issue because normally this data has never been collected before, so could take more time the first time
Census data for active employees
Could include: name, employee ID, DOB, DOH, sex, coverage information, marital status, salary (if applicable)
Census data for retirees
Could include: name, ID#, DOB, sex, coverage information, marital status
Claims and/or premium data to set claims costs
Effect of HIPPAA on obtaining employee data
Concerns with distribution of protected health information (PHI)
35. Selection of Actuarial Assumptions and Procedures Demographic assumptions
Mortality
Turnover
Retirement age
Marital status
Should be consistent with those used for pension accounting where entity also has a pension plan
Economic assumptions
Discount Rate – depends on “funding”
Health care cost trend
Depends on plan experience and benefits offered
May be different for pre-65 and post-65 benefits
Typically, grades down over a period of years
Salary increases (where applicable)
36. Actuarial Assumptions In general
Same assumptions should be used for plan financials (GASB 43) and sponsor financials (GASB 45) for same or related information
Actual experience should be used if credible, but experience must by analyzed for anomalies and reasonableness
Reasonableness of each assumption should be independently assessed (each one should be reasonable on its own)
Each assumption should also be consistent with other assumptions (e.g., underlying inflation component of discount rate and salary increase assumptions)
37. Actuarial Assumptions Liability discount rate (investment return rate)
Long-term investment yield on assets that will be used to pay benefits
Based on plan assets, if funded, or
Employer assets if pay-as-you-go, or
Combination/blend if plan is partially funded
OPEB expense will very likely be higher if plan is not funded
Consider differences in discount rates for funded and unfunded arrangements
38. Actuarial Assumptions Medical trend
Medical trend in past few years has been in range of 10% - 15%+
Claims costs
Should be based on expected actual claims costs and expenses associated with current and future retiree population (not the insurance premium for an insured plan due to subsidy involved)
If in community-rated plan, rates reflect experience of all those participating in plan, and same premium is charged for all of those in plan (active and retired), can use premium as basis for claims costs
Demographic Assumptions
“Likelihood” of receiving benefits
Termination, disability, retirement and death
Marital status, percentage electing spousal coverage
39. Selection of Actuarial Cost Method and Procedures Actuarial Cost Method
Several acceptable choices – unlike accounting standard for “private sector” OPEB arrangements
With sufficient lead time, can model costs under different alternatives
Amortization of initial obligation
Have some flexibility in choosing amortization approach
Period of up to 30 years
Numerous potential methods, should discuss with actuary
40. More on Actuarial Cost Methods The cost method determines the allocation or attribution of the actuarial present value of benefits to different periods of time
Plan costs in the long run are the plan benefits that are ultimately paid, so the method just allocates those costs to periods in different ways
Method selected will impact the OPEB cost
Differences in attribution can vary greatly depending on plan specifics; should discuss with plan actuary to understand differences applicable to the specific plan and alternatives available
41. Example – Full Valuation Substantive Plan
Large municipality has self-funded medical plan providing postretirement benefits
Benefits are paid from the Government’s general assets
Approx. 4,300 active employees with annual payroll of $175 million and 600 retirees
Each retiree pays 20% of the average active/retiree cost of the plan ($300/month for single coverage)
Under GASB 45, Sponsor’s OPEB Commitment is:
To pay 80% of average active/retiree plan cost for each retiree
To pay retiree claim costs in excess of avg. active/retiree plan cost
Assumed investment return assumption 4½ %
Low rate due to unfunded status of plan
42. Example #1 – Impact on Expense
43. Example 1A – Impact on Government-wide Statements
44. Questions?