Now that we have pension accounting under our belt, it is time to take the same concepts and implement the Other Postemployment Benefits under GASB 75 guidance. There are important aspects to consider when implementing GASB 75 that will be a little different for most of the governments that implemented pension accounting.
Plan types
Lets revisit what the different plan types are available. Single-Employer Plans are when there is only one employer in the plan, with all plan assets and cost benefits only belonging to that one employer. Agent-Multiple Employer Plans are when plan assets are pooled among multiple “single-employer plans” for investing and administrative purposes, but the assets are still accounted for separately for each plan. Cost-sharing multiple-employer plans are when plan assets are pooled along with their obligations to provide for the benefit plan. Most government agencies in California are either participating in CERBT OPEB Trust through CalPERS, which would be reported as an Agent Multiple-Employer Plan, or through PARS, which could be reported as a Single-Employer Plan or an Agent Multiple-Employer Plan. The plan type depends on if your Trust Assets are pooled in an investment fund or separately invested in its own trust investment fund (consult with your OPEB Trust Agreement). There are other Section 115 OPEB Trusts as well, such as PFM, which provide Single-Employer Plans with separate investing for each employer. Lastly, many governments continue to pay-as-you-go and not fund a Section 115 Trust fund at all, which would be a Single-Employer Plan.
Valuation vs. Measurement Dates
For pensions, the majority of the plans were in CalPERS and these decision dates were decided for you. Now for OPEB plans, these dates are much more dependent on the employer preference as long as they still fall within the GASB 75 guidelines. The Valuation Date must be within 30 months and 1 day, meaning for June 30, 2018, your valuation must be January 1, 2016 or later. The measurement date must be within 12 months, meaning if you had a January 1, 2016 valuation date, it would have to be rolled to June 30, 2017 or later. Remember, when you pick your measurement date, it needs to be consistent from each year forward. These dates need to be carefully considered, since you need a valuation at least biennially, but annually is encouraged. If a government is considering obtaining a biennial valuation, it would be advantageous to have a valuation date of June 30, 2017 with a measurement date of June 30, 2017 and June 30, 2018. This would allow them to meet the valuation (within 30 months and 1 day) and measurement date (within 12 months) requirements but get one report. This should be discussed with your actuary.
Employer reconciliation responsibility
Just as the pension census data is the responsibility of the employer to be reconciled each year, it is also the responsibility of the Employer to reconcile the OPEB census data. Key assumptions are to be checked and verified by the Employer; since the actuarial valuation is only as good as the data received by the actuary. The Actuary requests a variety of information from the employer, such as current employees information (birth date, male/female, hire date, health premium rate, etc) which they use for their assumptions and are the OPEB liability. The Employer should receive census data from their actuary to verify against their system. Additional audit steps will take place this implementation year to verify the census data accuracy and assess the internal controls the Employers have in place over the census data to verify the liability is being valued correctly.
Reporting
OPEB obligation reporting is very similar to the pension obligation reporting. The CalCPA Government Accounting and Auditing Subcommittee issued in February 2018 a California Committee on Municipal Accounting White Paper with example footnote and journal entries to help government agencies implement the GASB 75 accounting. The white paper can be found on the CalCPA website or HERE.
For more GASB 75 information contact expert, Deborah Harper, at (714) 672-0022.
