401(k) Plan Audit Cost
Written by True Tamplin, BSc, CEPF®
Updated on July 21, 2022
If you are an employer that offers a 401(k) plan to your employees, then once your plan reaches a certain size, it will need to be audited on a periodic basis.
If the word audit makes you cringe, don’t worry, because this type of audit is just a routine part of sponsoring a qualified plan.
A 401(k) audit is conducted by a third-party administrator (TPA) and must be done whenever a given plan meets certain criteria as outlined in ERISA (The Employee Retirement Income Security Act).
The audit is conducted in order to ascertain whether the plan is being run correctly and whether it is financially sound.
Audits are performed by a qualified public accountant who will examine your 401(k) plan documents and records in order to ensure that you are compliant with all IRS and ERISA guidelines.
He or she will also determine whether the information that you are submitting to the IRS every year on Form 5500 is accurate and correct.
ERISA Criteria
ERISA mandates that any plan that has at least 100 eligible participants at the beginning of the plan year (usually January 1st) must be audited.
It is key to remember that not all employees may be eligible to participate in a 401(k) plan.
For example, part-time employees are often ineligible to participate, as are independent contractors and other types of workers who are not full-time W2 employees.
But eligible employees do not have to actually participate in the plan in order to be counted.
And Cook Martin Poulson’s website lists the the following three types of plan participants who are not current employees that the IRS says must also be counted:
- Active employees: This category covers both employees currently covered under the plan as well as those who are eligible but who do not currently participate in the plan.
- Retired or separated: This category includes retired plan participants who either receive plan benefits or are eligible to receive said benefits. It also includes employees who have left your employ but still have active plans with you.
- Deceased: This category includes deceased former employees with one or more beneficiaries who receive plan benefits or are entitled to receive plan benefits.
Eligible employees are counted if they fall into one of the above categories as of the end of the prior tax year.
Finally, if your company falls within the 80-120 rule, then you don’t need to be audited until the number of eligible employees exceeds 120 for the year.
If your company employs fewer than 100 eligible participants in a given year and then exceeds 100 participants the next year (but less than 120), then you don’t need to be audited.
This can continue until you have at least 120 eligible employees.
But as long as you have less than 120 eligible employees, then you can continue to file as a “small” plan indefinitely.
How Can I Prepare for an Audit?
First, you’ll need to know what auditors generally examine when they audit a qualified plan.
According to Inovapayroll.com, the list includes the following:
- Reviewing of 401(k) plan documents provided by you to verify your plan is compliant with IRS and DOL rules
- Looking for any amendments made to the plan during the year
- Determining the accuracy of information reported on Form 5500, Annual Return/Report of Employee Benefit Plan, and 401(k) financial statements
- Assessing how your company maintains electronic 401(k) records
- Examining employee contributions to ensure money was remitted in a timely way
- Confirming distributions and rollovers were paid out properly
- Sampling specific participants’ transactions to further ensure compliance
- Interviewing upper management to vet any concerns
Next, you’ll need to get all of your documents in order and ready to be scrutinized.
The auditor will ask you for your plan documents, payroll data, and time-stamped communications.
Having these ready at hand can save you a lot of time and frustration.
It is also a good idea to integrate your payroll and record-keeping systems so as to minimize potential errors.
Finally, you need to be sure to enlist the help of a reputable plan administrator to oversee your plan when you first establish it so that you can be warned of potential trouble areas before the audit begins.
A good administrator should also be able to provide you with plan documents, financials, payroll data, valuations, and other information as requested by the auditor.
How Much Does an Audit Cost?
The cost of an audit can be borne by the plan.
You are not required to pay for the audit, although you can if you want to.
HealthEquity.com reports in its blog that “For small to medium size businesses (plans under $50 million in assets), we see average annual audit costs of $8,000 – $12,000. We have even seen auditors that charge over $18,000 for a plan audit.”
The actual cost of an audit can vary depending upon several different factors, but the real question is who has to foot the annual bill.
401(k) Plan Audit Cost FAQs
401(k) Plan | A Complete Beginner's Guide
401(k) Meaning
The 401(k) retirement savings account got its name from the Revenue Act of 1978, where an addition to the Internal Revenue Services (IRS) code was added in section 401(k). Consequently, 401(k) does not stand for anything except for the section of IRS tax code it was created in.
Traditional 401(k) vs Roth 401(k)
There are two types of 401(k) plans: Traditional and Roth 401(k)s. The traditional 401(k), named after the relevant section of the IRS code, has been around since 1978. With this plan, any contributions you make to the 401(k) account will reduce your income taxes for that year and will be taxed when they are withdrawn. Roth 401(k)s, named after former senator William Roth of Delaware, were introduced in 2006. Unlike a traditional 401(k), all contributions are made with after-tax dollars and the funds in the Roth 401(k) account accrue tax free. Typically, employees can take advantage of both plans at the same time, which is recommended among financial advisors to maximize retirement savings. Because of the way the contribution limits work, it is possible to invest different amounts into each account, even year-to-year, so long as the total contribution does not exceed the set limit.
Contributing to Your 401(k) Retirement Plan
Contributing to a 401(k) plan is traditionally done through one’s employer. Typically, the employer will automatically enroll you in a 401(k) that you may contribute to at your discretion. If you are self-employed, you may enroll in a 401(k) plan through an online broker, such as TD Ameritrade. If your employer offers both types of 401(k) accounts, then you will most likely be able to contribute to either or both at your discretion. To reiterate, with a traditional 401(k), making a contribution reduces your income taxes for that year, saving you money in the short term, but the funds will be taxed when they are withdrawn. With a Roth 401(k), your contributions can be made only after taxation, which costs more in the short term, but the funds will be tax free when you withdraw them. Because of this, deciding which plan will benefit you more involves figuring out in what tax bracket you will be when you retire. If you expect to be in a lower tax bracket upon retirement, then a traditional 401(k) may help you more in the long term. You will be able to take advantage of the immediate tax break while your taxes are higher, while minimizing the portion taken out of your withdrawal once you move to a lower tax bracket. On the other hand, a Roth 401(k) may be more advantageous if you expect the opposite to be true. In that case, you can opt to bite the bullet on heavy taxation today, but avoid a higher tax burden if your tax bracket moves up. Check out this article from Forbes to see the IRS tax rate tables for 2020, but remember that they are subject to change. A smart move may be to hedge your bets and divide your contributions between the two types of IRAs. If your employer allows you to add funds to both a traditional and Roth 401(k), then doing so reduces the potential risks of each. In this case, you will also have the ability to decide what proportion of your income goes into each account, meaning that as you near retirement and have a clearer idea of what position you will be in, you can put more into one or the other. When you do decide which avenue to take, make sure to thoroughly evaluate your decision. Moving funds from one account to another, such as from a traditional to a Roth 401(k), is time consuming and expensive, if even possible. Likewise, transferring a 401(k) from one employer to another in the event of a job change is also tricky. You want to make sure that when you put money into your plan, it will be able to sit undisturbed for a very long time.
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About the Author
True Tamplin, BSc, CEPF®
True Tamplin is a published author, public speaker, CEO of UpDigital, and founder of Finance Strategists.
True is a Certified Educator in Personal Finance (CEPF®), a member of the Society for Advancing Business Editing and Writing, contributes to his financial education site, Finance Strategists, and has spoken to various financial communities such as the CFA Institute, as well as university students like his Alma mater, Biola University, where he received a bachelor of science in business and data analytics.
To learn more about True, visit his personal website, view his author profile on Amazon, or check out his speaker profile on the CFA Institute website.