Groom principal Kelly Geloneck joined PLANSPONSOR Magazine for their cover feature, “Risk Protection” where she discussed plan compliance and operational reviews.
In the article, Geloneck stated, as reiterated by PLANSPONSOR, “Plan compliance reviews can vary widely in their depth and scope.”
“Before beginning a compliance review, we talk to the client about its preferred scope for the review: Is this just a review of the plan documents, to make sure they are up to date and compliant with IRS and Department of Labor guidance? Or does the client also want a plan operational review to confirm the plan is being operated in accordance with the plan documents?” Geloneck said. PLANSPONSOR reported further stating, “If the sponsor prefers a full operational review, Groom typically will begin that by requesting a broad range of plan documentation. The law firm then reviews the documents, to confirm whether they have been updated for required amendments since the plan’s last IRS determination letter and to see whether plan communications to participants are aligned with plan provisions, Geloneck says.”
PLANSPONSOR continued, “Groom will then meet with the sponsor to talk in more depth about the plan’s current governance structure and operations. Geloneck often will ask questions that mirror those the DOL asks plan sponsors when it performs a plan audit. For example: Who are the fiduciaries serving as plan administrators? How were they appointed? And is there documentation to reflect the appointments? Other questions may focus on the frequency of fiduciary meetings and whether records of meeting minutes have been retained.”
PLANSPONSOR added, “If a plan has made specific errors, such as late employee enrollment, Geloneck suggests dealing with those issues first.”
“Typically, you’re putting out the immediate fires first and then looking at the broader issues,” Geloneck said, adding “Looking at the broader issues tends to be a longer process but can result in significant savings and administrative efficiencies for the plan later.”
To read the article, click here.