Industry Insights

GASB Proposes Significant Changes for Pension Plan Accounting & Calculation

January 2012
By:  Melissa Tuttle

Melissa Tuttle

Manager

Manufacturing & Distribution

Wells Fargo Center
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Denver
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Updated January 27, 2012, 3:30 p.m.

In June 2011, the Governmental Accounting Standards Board (GASB) issued for public comment an exposure draft of a proposed statement, Accounting and Financial Reporting for Pensions, an amendment of GASB Statement No. 27. The proposed statement would amend the requirements of Statement No. 27, Accounting for Pensions by State and Local Governmental Employers, and Statement No. 50, Pension Disclosures, as they relate to governmental employers that account for pensions provided through trusts, or equivalent arrangements, that meet certain criteria. The proposed statement includes guidance for accounting for participating employers in single-employer and multiple-employer defined benefit pension plans, cost-sharing plans, defined contribution plans and plans with insured benefits. The note disclosure and required supplementary information requirements for employers whose employees are provided with defined benefit pensions through qualified trusts also are addressed. GASB 27 and 50 would remain applicable to employers whose pensions are not covered by the scope of this proposed statement. 

With the original September 30 comment deadline extended until October 14, 2011, more than 600 comment letters were submitted, indicating strong public interest in the pension accounting and financial reporting issues addressed in the exposure draft. GASB began deliberating the issues raised in the comment letters during its December 2011 meeting and is expected to continue deliberations through May 2012, with a final statement issued in June.

GASB simultaneously issued and is deliberating a related exposure draft of a proposed statement addressing plans’ accounting and financial reporting for state and local government pensions (an amendment to GASB Statement No. 25). The two proposed statements are closely related in many areas.

If passed as currently written, the proposed statement will trigger significant changes in accounting and reporting of pension benefits, including what is reported and how it is calculated. This includes new procedures for measuring and recognizing obligations associated with pensions, pension costs and deferred outflows or inflows of resources. It also includes changes in the methods and assumptions used to project pension payments, discount projected payments to their present values and attribute those present values to periods of employee service. 

The changes would require many governments to recognize a much larger pension liability than is currently being reported. Current standards are closely related to how governments fund pensions, and liabilities essentially are designed to reflect to what extent a government has complied with its policy for funding pensions. The proposed standard is designed to recognize pension liabilities that reflect the entire unfunded portion of pension obligations regardless of when the government intends to fund the obligations. In addition, the proposed standard would require future pension obligations to be discounted to present value using a blended discount rate that reflects both the long-term investment expected rate of return for the portion of the obligations funded by existing net pension assets and a government’s long-term borrowing rate for the unfunded portion of future pension obligations. Current standards require the discount rate to reflect only the long-term investment expected rate of return. Because pension investments generally yield greater returns than governments’ long-term borrowing rates, the discounted net present value of pension obligations would be larger under the proposed standards to the extent the pension obligation is unfunded.

Cost-Sharing Employers

Under the proposed standards, a cost-sharing employer whose employees receive pensions through a qualified trust would report a net pension liability, deferred outflows or inflows of resources related to pensions, and pension expense based on its proportionate share of the collective net pension liability of all employers in the plan. The share of collective net pension liability recognized by an individual employer would be based on its expected long-term contribution effort to the plan as a proportion of all expected employer-related contributions. The measurement of collective net pension liability, pension expense and other key information would follow the same standards that apply to single and agent employers. The effects of changes to an employer’s expected proportion of total employer-related contributions—as well as the effects of differences between the expected and actual proportionate share of total employer-related contributions each period—would be reported as a deferred outflow or inflow of resources and recognized in the employer’s pension expense in a systematic and rational manner over a closed period representative of the expected remaining service lives of employees, beginning with the period of adoption. Under the current standards, governments recognize only the portion of cost-sharing pension obligations related to their annual required contributions.

Special Funding Situations

In some pension plans, an entity other than the employer government is legally responsible for contributing to the plan. The legal responsibility to contribute is either conditional based on a particular event or circumstance unrelated to the pension plan or unconditional.

An unconditional responsibility might be a requirement to contribute a certain percentage of the employer government’s covered payroll. Under an unconditional special funding situation, the funding government legally responsible for contributing has assumed a portion of the employer government’s pension obligation as its own. Consequently, the funding government would recognize its proportionate share of the net pension asset or liability, deferred inflows or outflows of resources and pension expense under the proposed standard. The employer government would calculate its net pension liability and related financial statement elements, prior to the funding government’s support, but would recognize amounts net of the funding government’s proportionate share. The employer government would recognize “on behalf” revenue equal to the portion of the funding government’s pension expense related to the employer government’s employees.

On the other hand, conditional special funding situations would be accounted for in a manner similar to grants. The recipient government would recognize the contribution from the other government as revenue. The funding government would recognize the contribution as an expense, but not as a pension expense. 

Summary of Significant Changes

Under the current guidance, single and agent employers are already including certain note disclosures in the government’s financial statements and recognizing pension cost equal to the actuarial calculation of the employer’s annual required contribution adjusted by the net pension obligation for past under- or over-contributions.  As these employers are already recognizing and measuring a pension cost and a pension liability based on an actuarial valuation, the anticipated impact of the proposed changes on these employers should be less than the impact on cost-sharing employers.  Although the impact is anticipated to be less on single and agent employers, if issued, all employers would need to comply with the relevant requirements in the proposed standard, such as using a blended discount rate, including discretionary cost-of-living adjustments (COLAs) that are substantially automatic, and using the entry age normal cost allocation method.

Below is a summary of selected significant differences between the current and proposed guidance by GASB for accounting and financial reporting of cost-sharing multiple-employer defined pension benefits:

Current

Proposed

Implication

  • Pension expense is based on contributions made (pay-as-you-go basis) or based on a contractually required amount, which can be determined either by statute, by contract, or on an actuarially determined basis.

 

The following inputs, unless noted otherwise, will be included in pension expense in the current period:

  • Employees’ service cost attributed to the current period in the actuarial valuation
  • Interest on total pension liability (TPL)
  • For active and inactive employees, changes in TPL due to changes in benefit terms
  • Effects of differences between expected and actual experience and the effects of changes of assumptions should be recognized as follows:
    1. To the extent that effects relate to the TPL of inactive employees (including retired employees), the effects should be recognized immediately
    2. To the extent that effects relate to the TPL of active employees, should be recognized as a deferred outflow or inflow of resources and recognized in pension expense based on the weighted average of the remaining employment of active employees with which the change is associated
  • Projected earnings on plan investments
  • Difference between actual investment earnings and projected earnings will be deferred and recognized as expense over a five-year period beginning in the period in which the difference occurred
  • In general, all other changes should be included in expense in the period of change
  • Earlier recognition of pension expense
  • Increased comparability of reported pension information
  • Recognition of liability and expense as benefits earned by employees

 

  • A government sponsor only reports a liability to a pension plan if the government sponsor’s contribution to the plan is less than the contractually required amount. This method does not take into account when benefits are earned (when service is provided by employees).
  • TPL is the portion of the actuarial present value of projected benefit payments that is attributed to past periods of employee services.
  • The cost-sharing employer is responsible for a proportionate share of the collective TPL not covered by pension assets, which is an unfunded obligation, and the entity should report its portion of the amount as a net pension liability (NPL) on the statement of net position. NPL is calculated as TPL less plan net assets.
  • Other government liabilities to a pension plan, such as contributions due but not yet paid, would be reported separately from the NPL.
  • The addition of this long-term liability to the statement of net assets will reduce unrestricted net assets.
  • Cost-sharing entities will have to calculate their portion of NPL and record NPL and pension expense as well as disclose plan information.
  • Actuarial valuation is not required by GASB.
  • The TPL needs measured as of each cost-sharing employer’s year-end, and an actuarial valuation must be completed at least biennially. TPL can be from either an actuarial valuation as of the cost-sharing employer’s year-end or from updated procedures rolling forward amounts from an actuarial valuation as of a date no more than 24 months earlier.
  • Newly required by GASB, although employers might have been using this method previously.
  • Although actuarial valuations are not required by GASB, if a pension plan used actuarial valuations, in practice, the long-term rate of return on assets is used for the discount rate.
  • As long as plan assets are projected to be sufficient to make projected benefit payments, governments would discount projected benefit payments using the long-term expected rate of return.
  • If plan assets are projected not to be available to be invested long-term and, therefore insufficient for paying benefits, then governments would need to incorporate into the discount rate a 30-year, high-quality, tax-exempt municipal bond index rate to the extent projected benefits are unfunded.
  • As current tax-exempt municipal bond rates are low and projected benefit payments are discounted using a blended rate that includes this rate, the actuarial present value will be greater and the net pension liability larger.
  • Although actuarial valuations are not required by GASB, in general, if a pension plan used actuarial valuations, only automatic cost-of-living adjustments (COLAs) were typically included in liability and expense calculations.
  • Automatic COLAs and discretionary COLAs that are substantially automatic are included in the calculation.
  • This will increase NPL.
  • If an actuarial valuation was used, a choice of various actuarial methods was allowed.
  • The only actuarial method allowed to allocate the discounted present value over a period will be the entry age normal cost allocation method.
  • Attribution of the present value of benefit payments should be done as a level percentage of projected payroll.
  • This will increase comparability of reported pension information.
  • Note disclosures currently include required contribution rates of the employer in dollars and the percentage of that amount contributed for the current year and each of the two preceding years, and how the contractually required contribution rate is determined, or that the cost-sharing plan is financed on a pay-as-you-go basis.

 

Governments participating in pension plans would disclose the following (this list is not all inclusive):

  • Description of benefits
    • Name of the plan
    • Description of the benefit provisions  
    • Classes of employees covered
    • Whether a stand-alone pension plan financial report is available and, if so, how to obtain it
  • Net pension liability information
    • Significant assumptions used in the measurement of the TPL
    • Detailed information about the discount rate (including a sensitivity analysis that shows the effect on the NPL of a 1 percentage point increase and a 1 percentage point decrease in the discount rate)
    • Proportion used to determine its recognized amounts
  • Plan net position information
    • Elements of the plan’s basic financial statements (or, if available, information on how to obtain the plan’s financial statements and whether same basis is used)
  • Other information
    • Policy for determining annual contribution
    • NPL, deferred outflows and deferred inflows of resources related to pensions, and pension expense
    • Date of actuarial valuation
    • Description of changes of assumptions or benefit terms that affect TPL
    • Individual components of NPL, deferred outflows and deferred inflows of resources
    • Individual components of the current period pension expense
    • On-behalf revenue recognized under a special funding situation
  • Cost-sharing employers will present detailed plan information.
  • This will increase comparability of reported pension information.
  • Required supplementary information (RSI) currently includes a schedule of funding progress and employer contributions for the plan, unless the financial statements of the plan are publicly available.  RSI also currently includes a disclosure that the information presented relates to the cost-sharing plan as a whole and it provides information to facilitate understanding the scale of the information presented relative to the individual employer.

Governments participating in pension plans would present the following (this list is not all inclusive):

  • 10-year schedule containing information about the changes in the collective NPL
  • 10-year schedule, measured at the collective level, including, TPL, plan net position, NPL, ratio of plan net position to TPL, amount of covered payroll, NPL as a percent of covered payroll
  • 10-year schedule presenting detailed information at the individual-employer level
  • If an actuarial calculated employer contribution is determined, 10-year schedules presenting actuarial information at the collective level and at the individual-employer level
  • Notes to the schedules
  • Cost-sharing employers will present all schedules for the participants as a whole, and certain schedules will also be presented with information for their proportionate share.

Effective Date & Transition
The final statements are anticipated to be issued in June 2012, with an effective date of periods beginning after June 15, 2012, for certain employers (generally single-employer plans that have a plan net position in excess of $1 billion). The effective date for all other employers is anticipated to be for periods beginning after June 15, 2013, although earlier application likely would be encouraged. To the extent practical, accounting changes made to comply with this statement would be reported as adjustments of prior periods, and financial statements presented for the periods affected should be restated.

For more on how these changes could affect your organization, contact your BKD advisor.

Executive Summary
A proposed statement from the Government Accounting Standards Board includes guidance to governments that participate in pension plans, which could trigger significant changes in accounting and reporting of pension benefits, including what is reported and how it is calculated.