GASB Issues Statement No. 82 - Pension Issues Amending GASB Statements No. 67, No. 68, and No. 73
The Governmental Accounting Standards Board (GASB) issued Statement No. 82, which addresses certain pension issues raised by stakeholders under Statements No. 67, No. 68, and No. 73. In general, the issues are related to the presentation of payroll-related measures, deviations from actuarial standards of practice, and classification of member contributions. Specifically, Statement No. 82:
- Supersedes Implementation Guide No. 2015-1, Questions 5.75.1, 5.154.1, and 5.192.2, and
- Amends Statement No. 67, paragraphs 32 and 51, and footnote 2; Statement No. 68, paragraphs 15, 46, 81, and 139, and footnote 2; Statement No. 73, footnote 2; and Implementation Guide 2015-1, Questions 5.97.2, 5.154.2, 5.192.1, and 5.192.3.
The primary purpose of Statement No. 82 is to improve financial reporting by enhancing consistency in the application of financial reporting requirements to certain pension issues. The provisions of Statement No. 82 are not required for immaterial items.
This alert summarizes the key provisions of Statement No. 82, a copy of which is at this link.
Action Needed Now: Affected plans and plan sponsors in consultation with their auditors and actuaries need to determine whether any changes are needed for future financial reporting and if any of the changes require prior financial statements to be restated to meet the statement's requirements for the classification of employer paid member contributions or the presentation of payroll-related measures.
Changes Made by Statement No. 82
Statement No. 82 addresses the following three areas:
- Presentation of Payroll-Related Measures in Required Supplementary Information
Prior to the issuance of Statement No. 82, Statements No. 67 and No. 68 required presentation of covered-employee payroll (i.e., the total payroll of employees that are provided with pensions through the pension plan) and ratios based on covered-employee payroll in the schedules of required supplementary information. Statement No. 82 amends Statements No. 67 and No. 68 to require instead the presentation, and use, of covered payroll, which is the payroll on which contributions to a pension plan are based.
- Selection of Assumptions
- Classification of Employer-Paid Member Contributions
With respect to pension plan contributions made by an employer to satisfy contribution requirements identified under the plan as plan member contribution requirements1, Statement No. 82 provides that:
- For purposes of applying Statement No. 67, those amounts should be classified as plan member contributions, and
- For purposes of applying Statement No. 68, including for purposes of determining a cost-sharing employer's proportion, those amounts should be classified as employee contributions.
Statement No. 82 clarifies that, for the purposes of selection of assumptions used in determining the total pension liability and related measures, a deviation (as the term is used in the Actuarial Standards of Practice issued by the Actuarial Standards Board) from the guidance in an Actuarial Standard of Practice is not considered to be in conformity with the requirements of Statement No. 67, Statement No. 68, or Statement No. 73.
In addition, an employer's expense and expenditures for those amounts should be recognized in the period for which the contribution is assessed and classified in the same manner as the employer classifies similar compensation other than pensions (for example, as salaries and wages or as fringe benefits).
For some plans, Statement No. 82 will not result in any changes. Some plans already treated employee and employer contributions as now required by Statement No. 82 and some plans do not use actual employer contributions for determining proportionate shares in a cost-sharing plan. Also, some plans used pensionable compensation rather than total compensation of covered employees for purposes of Statements No. 67, 68, and 73 for prior years. These plans would appear to comply with the changes made by Statement No. 82.
Although earlier adoption is encouraged, Statement No. 82 generally is effective for reporting periods beginning after June 15, 2016. However, plan sponsors should note the following specific provisions:
- The requirements relating to the selection of assumptions in a circumstance in which an employer's pension liability is measured as of a date other than the employer's most recent fiscal year-end are effective for the first reporting period in which the measurement date of the pension liability is on or after June 15, 2017.
- Changes adopted to conform to the Statement's requirements for classification of employer paid member contributions should be applied retroactively by restating financial statements, if practicable, for all prior periods presented. If restatement for prior periods is not practicable, the cumulative effect, if any, of applying Statement No. 82 should be reported as a restatement of beginning net position (or fund balance or fund net position, as applicable) for the earliest period restated. For the first period that Statement No. 82 is applied, the notes to the financial statements should disclose the nature of the restatement and its effect, and if applicable, the reason why prior periods presented are not restated.
- Changes adopted to conform to the requirements for the selection of assumptions apply on a prospective basis.
- Information required for the presentation of payroll-related measures, and the classification of employer paid member contributions, presented in 10-year schedules of required supplementary information should be restated for all years presented, if practicable. If restatement for prior years presented is not practicable, the reason for not restating prior years should be presented in notes to the applicable schedule.
GASB addressed issues that stakeholders had raised concerning the disclosures and presentations required under Statements No. 67, No. 68, and No. 73. The resolution of the issues by Statement No. 82 better aligns the reporting with the information used by actuaries in determining costs and liabilities for defined benefit plans. If a plan sponsor was treating employee contributions that were "picked-up" as employer contributions, then the impact of Statement No. 82 needs to be evaluated. An evaluation of the impact is especially needed if employer contributions are used as the basis for determining each employer's proportionate shares of the costs under a cost-sharing arrangement.
Cheiron pension consultants can assist you in analyzing the impact of GASB Statement No. 82 on your defined benefit plans.
Cheiron is an actuarial consulting firm that provides actuarial and consulting advice. However, we are neither attorneys nor accountants. Accordingly, we do not provide legal services or tax advice.
1Such amounts are often referred to as employee contributions that have been "picked-up" by the employer pursuant to Internal Revenue Code section 414(h)(2).