Make Sure Your Annual Census Report Is Accurate

Employee Benefit Plan Audit | September 25, 2019 | Holtzman Partners

Each year, you are responsible for providing a comprehensive census report to your third-party administrator (TPA) and other relevant service providers. The census report is the starting point for your plan’s audit, so it’s critical to ensure that the data is accurate, timely and complete.

Not submitting accurate employee data could lead to a host of problems—including possible failure of annual non-discrimination tests. Here are a few things to keep in mind as you prepare your annual employee census:

  • Include your entire employee population. This includes employees who are eligible and ineligible to participate in your plan.
  • Correctly identify employees as union or non-union because union employees are often excluded from plans and need to be segregated for testing.
  • List both employee and employer contribution amounts to the plan for the year.
  • Pay especially close attention to details such as employees’ birthdays and dates of hire. Errors in these seemingly simple areas can lead to big problems.
  • Make sure that former employees who no longer work for your company have been deleted from the census.

Also, confirm that the total amount of annual compensation in the census meets the definition of compensation in the plan document. If total compensation in the census doesn’t match the amount reported as gross wages on payroll reports, these should be reconciled as a test to prove the accuracy and completeness of the census information.

Once your census is complete, reconcile the total annual compensation and employee contribution data with your annual payroll data. Then choose a random sample of employees and confirm that the data contained in the census matches the data contained in their personnel files.

Have more questions about your census report? Give our employee benefit plan team a call at 512.610.7200—we’d be happy to answer them for you.

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