Project Pages

Other Postemployment Benefit Accounting and Financial Reporting

Project Description: The Board will consider the potential improvements to the existing standards of accounting and financial reporting for other postemployment benefits (OPEB) by state and local governmental employers and by the trustees, administrators, or sponsors of OPEB plans. One objective of this project is to improve accountability and the transparency of financial reporting in regard to the financial effects of employers’ commitments and actions related to OPEB. Another objective of this project is to improve the usefulness of information for decisions or judgments of the various users of the general-purpose external financial reports of governmental employers and OPEB plans. This project also will address accounting and financial reporting for postemployment benefits that are not provided through a trust that meet6s the criteria in paragraph 4 of GASB Statement No. 68, Accounting and Financial Reporting for Pensions, as well as clarifying amendments to Statement No. 67, Financial Reporting for Pension Plans, and Statement 68.

Status:
Currently being deliberated
Exposure Drafts Approved: May 2014
Added to Current Agenda: April 2011

Other Postemployment Benefit Accounting and Financial Reporting—Project Plan


Background: This project will assess the effectiveness of the OPEB standards by examining the related OPEB standards—Statement No. 43, Financial Reporting for Postemployment Benefit Plans Other Than Pension Plans, and Statement No. 45, Accounting and Financial Reporting by Employers for Postemployment Benefits Other Than Pensions. The Board’s approach to date has been to apply a common framework to accounting and financial reporting for all postemployment benefits, including both pensions and OPEB. This project will consider many of the same developments and issues encompassed by the pension project.

Conceptual Developments. Relevant conceptual points of reference that were not available when the pension standards were developed were not applied as Statements 43 and 45 were being developed in order to align the pension and OPEB standards. These concepts include:
  • The definition of a liability in Concepts Statement No. 4, Elements of Financial Statements
  • The definition of communication methods—including recognition/display in basic financial statements, notes to basic financial statements, and required supplementary information (RSI)—in Concepts Statement No. 3, Communication Methods in General Purpose External Financial Statements That Contain Basic Financial Statements.
Other OPEB Accounting Standards. Other standards identified by the project staff as part of the research include:
  • Financial Accounting Standards Board (FASB)—Statement No. 106, Employers’ Accounting for Postretirement Benefits Other Than Pensions, as amended by Statement No. 158, Employers’ Accounting for Defined Benefit Pension Plans and Other Postretirement Plans
  • Federal Accounting Standards Advisory Board—Statement of Federal Financial Accounting Standards 5, Accounting for Liabilities of the Federal Government
  • International Public Sector Accounting Standards Board—International Public Sector Standard 25, Employee Benefits
  • International Accounting Standards Board—International Accounting Standard 19, Employee Benefits
  • Accounting Standards Board (ASB) of the United Kingdom—Financial Reporting Standard 17, Retirement Benefits
  • Public Sector Accounting Board of the Canadian Institute of Chartered Accountants—Public Sector Accounting Handbook Section PS 3250, Retirement Benefits
  • Australian Accounting Standards Board (AASB)—AASB 119, Employee Benefits.
Other Literature. Prominent in some discussions of OPEB accounting issues in accounting and actuarial arenas has been a view of OPEB reflecting the discipline of financial economics. Actuaries and financial analysts of that school of thought have expressed a distinctive analysis of OPEB benefits, the relationships among key parties having an interest in OPEB benefits, and the effects of accounting and financial reporting standards on decision making and the investment of plan assets. This view also has stimulated spirited response within the United States from some public OPEB actuaries that favor the traditional actuarial funding model.

State commissions, research groups, and consultants in various parts of the country have issued a number of studies of OPEB funding, governance, and other OPEB issues or problems that also may be useful as reference material for this project. The findings and recommendations of studies of this nature focus on particular facts and circumstances.

Accounting and Financial Reporting Issues
: The scope of this project includes issues (a) raised in the OPEB research and by participants in the pension accounting and financial reporting research project, (b) identified in literature on the subject, or (c) identified through the staff’s review of transactions and other events affecting OPEB in the application of existing standards by OPEB plans and employers, and the way that annual financial reports have reflected the effects of events in years since the effective dates of Statements No. 43, Financial Reporting for Postemployment Benefit Plans Other Than Pension Plans, and No. 45, Accounting and Financial Reporting by Employers for Postemployment Benefits Other Than Pensions. It also includes consideration of relevant conceptual developments by the Board subsequent to the issuance of Statements 43 and 45 in Concepts Statements No. 3, Communication Methods in General Purpose External Financial Reports That Contain Basic Financial Statements, and No. 4, Elements of Financial Statements. The scope of the project also includes consideration of more specific issues and potential improvements related to measurement, recognition, and disclosure of information about OPEB by employers and by OPEB plans. Tentative decisions reached with regard to pensions also will be considered in relation to postemployment benefits generally, consistent with the objective of maintaining a common approach and similar standards for all postemployment benefits to the extent appropriate.

The project also includes consideration of potential issues related to small governments, including issues related to the cost of implementation, and issues related to special-purpose entities, including comparability of accounting and financial reporting among governmental entities versus comparability among publicly and privately owned entities engaged in the same types of economic activity.

Project History:
  • Added to pre-agenda research: April 2011
  • Added to current technical agenda: April 2012
  • Task force established? Yes
  • Deliberations began: July 2012
  • Exposure Drafts approved: May 2014
  • Comment period: June–August 2014
  • Redeliberations began September 2014.
Current Developments: At its September, November, and December meetings and October teleconference meeting, the Board redeliberated issues raised by respondents to the Exposure Drafts, Accounting and Financial Reporting for Pensions and Financial Reporting for Pension Plans That Are Not Administered through Trusts That Meet Specified Criteria, and Amendments to Certain Provisions of GASB Statements 67 and 68, Accounting and Financial Reporting for Postemployment Benefits Other Than Pensions, and Financial Reporting for Postemployment Benefit Plans Other Than Pension Plans.

Work Plan:
February 2015 (T/C): Redeliberate component unit-related issues.
March 2015: Redeliberate note disclosures, required supplementary information, defined contribution, and other issues.

April 2015:

Review preballot drafts of final Statements.

June 2015:

Review ballot drafts and issue final Statements.


Other Postemployment Benefit Accounting and Financial Reporting—Recent Minutes


Minutes of Meeting, January 27-29, 2015

The Board continued deliberations on OPEB and pensions by discussing respondent concerns regarding which entities associated with OPEB and pension transactions are within the scope of the Exposure Drafts, Financial Reporting for Postemployment Benefit Plans Other Than Pension Plans (Plan Exposure Draft) and Accounting and Financial Reporting for Pensions and Financial Reporting for Pension Plans That Are Not Administered through Trusts That Meet Specified Criteria, and Amendments to Certain Provisions of GASB Statements 67 and 68 (Pension Exposure Draft). With regard to OPEB plans administered through trusts that meet the specified criteria, the Board tentatively agreed to clarify the scope of the final Plan Statement to emphasize that (1) the OPEB plan represents a financial reporting entity that potentially is broader than the transactions of a trust that holds assets for purposes of OPEB and (2) the final Statement does not establish requirements for entities that perform one or more functions that are associated with an OPEB plan but that are not the fiduciary for the OPEB plan (as a whole) and that those entities would continue to apply the financial reporting requirements of all other standards that are applicable to the transactions in which they engage.

With regard to OPEB and pension plans that are not administered through trusts that meet the specified criteria, the Board tentatively concluded that the scope of paragraphs 55 and 56 in the final Plan Statement and paragraphs 92 and 93 in the final Pension Statement should be clarified to indicate it is applicable to all entities that hold employer assets associated with OPEB or pensions. The Board also discussed requests for additional guidance for the financial statement presentation by employers of assets accumulated for OPEB or pensions. The Board tentatively decided not to provide additional guidance for the financial statement presentation by employers for assets used to pay OPEB or pensions that are provided through plans that are not administered through trusts that meet the specified criteria. The Board noted that discussion of this topic could potentially be expanded upon in the final Statement’s Basis for Conclusions. The Board then discussed concerns raised by some respondents regarding the readability and ability to apply the requirements in the Plan Exposure Draft related to determining the number of defined benefit OPEB plans that are administered through trusts that meet the specified criteria. The Board tentatively decided not to modify the requirements for determination of the number of defined benefit OPEB plans that are administered through trusts that meet the specified criteria. The Board also tentatively concluded that the final Employer and Pension Statements should not establish a requirement for the determination of the number of plans in circumstances in which OPEB or pensions are provided through plans that are not administered through trusts that meet the specified criteria.

Next, the Board considered OPEB plan reporting issues raised by respondents to the Plan Exposure Draft. The Board began this discussion with issues related to the statement of fiduciary net position. The Board tentatively agreed that the requirement for an OPEB plan to recognize a liability to employees for benefits to the extent that benefits are currently due and payable should be carried forward to the final Plan Statement. The Board then discussed the need to provide clarification regarding specific application guidance regarding deferred inflows and outflows of resources that would be included in a statement of fiduciary net position. The Board tentatively concluded not to include clarification in the final Plan Statement. The Board also tentatively agreed not to include clarification in the final Plan Statement regarding the meaning of “due pursuant to legal requirements” relative to recognizing contribution receivables of an OPEB plan. Next, the Board discussed issues concerning allocated insurance contracts and tentatively concluded not to include any additional clarifying guidance regarding the treatment of allocated insurance contracts that do not meet the criteria to be excluded from OPEB plan assets in the final Plan Statement. The Board also tentatively agreed that the requirement to report investments generally at fair value should be carried forward to the final Plan Statement.

The Board then discussed reporting issues related to the statement of changes in fiduciary net position. Respondents requested clarification of the requirement that benefit payments made directly by an employer exclude amounts paid by inactive members receiving benefits. The Board tentatively agreed to carry forward to the final Plan Statement the requirement to exclude amounts paid by inactive plan members receiving benefit payments from the amounts reported by the OPEB plan as contributions and benefit payments. The Board then discussed respondents’ requests for specific reference to the term implicit rate subsidy in the Standards section. The Board tentatively agreed that a specific reference to the implicit rate subsidy should not be made in the Standards section of the final Plan statement.

The Board noted that the Basis for Conclusions discussion about the requirements for reporting benefit payments should be expanded to include additional clarification of the effects of an implicit rate subsidy in the final Plan Statement. The Board also tentatively agreed that the requirement to recognize dividends from an allocated insurance contract excluded from OPEB plan assets as a reduction of benefit payments should be carried forward to the final Plan Statement. Next, the Board considered respondent comments regarding requirements for plans to present additional financial information. The Board tentatively concluded that multiple-employer OPEB plans should not be required to provide additional information as a basic financial statement, notes to basic financial statements, or required supplementary information about (1) each individual agent employer’s amount of the agent OPEB plan’s fiduciary net position or (2) each individual cost-sharing employer’s proportionate share of the net OPEB liability.

The Board then discussed issues raised by respondents to the Exposure Draft Accounting and Financial Reporting for Postemployment Benefits Other Than Pensions (Employer Exposure Draft), regarding the requirements related to cost-sharing employers. The Board began this discussion by addressing concerns specifically related to the recognition of OPEB liabilities by cost-sharing employers. The Board tentatively decided to carry forward the view to the final Employer Statement that a cost-sharing employer has an individual liability relative to the net OPEB liability for benefits provided through a cost-sharing OPEB plan. The Board then considered issues regarding the determination of a cost-sharing employer’s proportion. The Board tentatively agreed that the requirement that a cost-sharing employer’s proportion be determined as the relationship of the employer’s contributions relative to the contributions of all participating employers in the cost-sharing OPEB plan on a basis consistent with the manner in which contributions to the OPEB plan are determined should be carried forward to the final Employer Statement. The Board considered additional employer-specific measurements of an OPEB liability and tentatively agreed to carry forward to the final Employer Statement the requirement for a cost-sharing employer to report the net effect of a change in its proportion as a deferred outflow of resources or deferred inflow of resources related to OPEB and to recognize that amount in OPEB expense over a closed period representing the average remaining service life of all employees that are provided with benefits.

The Board then discussed issues raised by respondents regarding the definition of special funding situations and applying specific requirements in special funding situations. The Board tentatively agreed to carry forward the requirements for special funding situations in circumstances in which OPEB is provided through plans that are administered through trusts that meet the specified criteria to the final Employer Statement. The Board also tentatively agreed to carry forward the requirements for special funding situations in circumstances in which OPEB or pensions are provided through plans that are not administered through trusts that meet the specified criteria to the final Employer and Pension Statements. Additionally, some respondents requested clarification of the applicability of the requirement that special funding situations exclude circumstances in which resources are provided to the employer. The Board tentatively concluded not to include additional clarification of this criterion in the final Employer and Pension Statements but instead agreed to consider including scenarios explaining the criterion in a potential Implementation Guide. The Board then discussed a comment requesting additional examples to describe the criterion requiring that the amount of the benefit payments for which a nonemployer entity is legally responsible not be dependent upon events or circumstances unrelated to pensions. The Board tentatively agreed that additional examples relative to the criterion should not be included in the final Pension Statement. The Board also discussed the requirements for employers to recognize revenue and expense for support provided from nonemployer contributing entities not in a special funding situation only to the extent that the nonemployer contributing entity is making benefit payments as the benefits come due and tentatively agreed to carry forward the requirements to the final Employer and Pension Statements. In response to a respondent’s request for further clarification relative to individual adjustments that are required to be made by employers in special funding situations, the Board tentatively agreed not to include any further clarification in the final Employer and Pension Statements but instead concluded that expanded illustrations for this topic should be considered for a potential Implementation Guide. The Board concluded discussion of special funding situation issues by addressing a respondent’s request for additional illustrative guidance for OPEB not administered through a trust. The Board tentatively agreed not to include additional illustrations in the final Employer and Pension Statements related to special funding situations but instead decided to consider expanded illustrations for a potential Implementation Guide.

Next, the Board discussed issues related to the effective date of the final OPEB Statements. The Board tentatively agreed that all entities should be required to implement the final Plan Statement at the same time regardless of the size of the entity. The Board also tentatively agreed that all employers should be required to implement the final Employer Statement at the same time regardless of the size of the employer. The Board then discussed the effective dates of the final Pension, Plan, and Employer Statements. The Board tentatively concluded that the proposed effective dates in the Pension Exposure Draft should be carried forward to the final Pension Statement requiring implementation for fiscal years beginning after (1) June 15, 2015 for the amendments to Statements No. 67, Financial Reporting for Pension Plans, and No. 68, Accounting and Financial Reporting for Pensions, and for requirements related to assets held for pension plans that are not administered through trusts that meet the specified criteria and (2) June 15, 2016 for all other requirements related to pensions provided through pension plans that are not administered through trusts that meet the specified criteria. The Board also tentatively agreed that the proposed effective dates in the Plan and Employer Exposure Drafts should be delayed six months resulting in the final Plan Statement being effective for fiscal years beginning after June 15, 2016 and the final Employer Statement being effective for fiscal years beginning after June 15, 2017.

The Board then discussed issues related to using an alternative measurement method for the measurement of the total OPEB liability in the Employer and Plan Exposure Drafts. The Board began by tentatively agreeing to permit the use of an alternative measurement method in place of an actuarial valuation in circumstances in which OPEB is provided through plans with a small number of members. The Board also discussed potentially allowing an alternative measurement method for the measurement of the total pension liability and tentatively concluded not to permit the use of an alternative measurement method in place of an actuarial valuation in circumstances in which pensions are provided through plans with a small number of members. The Board then considered what threshold should be used to determine whether an employer could apply the alternative measurement method. The Board tentatively agreed that the threshold to apply the alternative measurement method for circumstances in which fewer than 100 employees (active and inactive) are provided with OPEB through an OPEB plan be carried forward to the final Employer and Plan Statements. The Board then discussed issues related to simplifications allowed by the alternative measurement method. The Board tentatively concluded that the final Employer and Plan Statements should allow for an employer that does not have historic age-based turnover data to use historic turnover data of a similar group that includes the employer’s covered group or the most recent experience of the employee group covered by the Federal Employees Retirement System as maintained by the U.S. Office of Personnel Management in the measurement of the total OPEB liability using the alternative measurement method. The Board also tentatively agreed that the final Employer and Plan Statements should carry forward the assumptions related to the determination of per capita healthcare rates when the same premiums are charged to active employees and inactive employees and age-adjusted premium information for inactive employees is not able to be obtained from the insurer or service provider that are based on (1) claims costs increasing 4 percent per year until age 65, (2) claims costs increasing 3 percent per year after age 65, and (3) claims costs experiencing a 50 percent reduction beginning at Medicare eligibility for OPEB plans with Medicare coordination. The Board then discussed the use of grouping in the measurement of the total OPEB liability using the alternative measurement method and tentatively concluded that the final Employer and Plan Statements should not include additional modifications to the proposal for grouping of employees based on common demographic characteristics. The Board also considered a request by a respondent to clarify the provisions related to the alternative measurement method that would limit which types of employers and OPEB plans can apply the alternative measurement method. The Board tentatively agreed that no modification should be made that would limit the types of employers and OPEB plans that can apply the alternative measurement method. The Board then considered a request by a respondent to include all necessary requirements to measure the total OPEB liability using the alternative measurement method in one section of the final Employer Statement. The Board tentatively concluded not to provide a section that includes all requirements to measure the total OPEB liability for employers that are eligible to apply the alternative measurement method in the final Employer Statement. The Board also tentatively agreed that requirements in the final Employer and Plan Statements for the alternative measurement method should not allow the use of a high-quality bond rate as a default rate for the discount rate. The Board then considered a request by a respondent to include reference to requirements related to the determination of the discount rate in the requirements related to using the alternative measurement method in the measurement of the total OPEB liability. The Board tentatively concluded that requirements related to the alternative measurement method in the final Employer and Plan Statements should not include an additional cross-reference, specific to the requirements for determination of the discount rate. The Board then considered a request by a respondent that the final Employer and Plan Statements allow an employer using the alternative measurement method to recognize differences between the projected and actual earnings on OPEB plan investments immediately in OPEB expense rather than over a five-year period. The Board tentatively concluded that the final Employer and Plan Statements should not allow these differences to be recognized immediately in OPEB expense. The Board also tentatively concluded that the final Employer and Plan Statements should carry forward the simplifications proposed in the Employer and Plan Exposure Drafts for which respondents did not provide comments. The Board then discussed whether additional illustrative guidance should be provided to assist in properly applying the alternative measurement method. The Board tentatively decided that the final Employer and Plan Statements should not provide additional illustrations and examples related to the measurement of an employer’s total OPEB liability using the alternative measurement method but instead concluded that this issue should be considered as a proposed question and answer for a potential Implementation Guide. Finally, the Board considered whether there should be a note disclosure requirement that would specifically state the alternative measurement method is a nonactuarial method. The Board tentatively concluded that when the alternative measurement method is used, the notes to the financial statements should provide that the measurements were not based on an actuarial valuation.

Minutes of Teleconference, January 5, 2015

The Board began deliberations by discussing concerns raised by respondents to the Exposure Drafts, Accounting and Financial Reporting for Postemployment Benefits Other Than Pensions (Employer Exposure Draft) and Accounting and Financial Reporting for Pensions and Financial Reporting for Pension Plans That Are Not Administered through Trusts That Meet Specified Criteria, and Amendments to Certain Provisions of GASB Statements 67 and 68 (Pension Exposure Draft) regarding recognition of expenditures and liabilities for postemployment benefits other than pensions (OPEB) and for pensions. The Board tentatively decided that the requirements related to recognition of liabilities and expenditures recognized in modified accrual financial statements related to defined benefit OPEB and pensions should be carried forward to the final Employer and Pension Statements. The Board also tentatively decided that the requirements related to liabilities and expenditures related to payables to a defined benefit OPEB plan, liabilities for insured benefits, and defined contribution OPEB and pensions recognized in modified accrual financial statements should be carried forward to the final Employer and Pension Statements.

The Board then reviewed a summary of the results of the alternative measurement method field test. No tentative decisions were made.

Minutes of Meetings, December 15-17, 2014

The Board reviewed and deliberated on issues discussed in the Exposure Drafts, Accounting and Financial Reporting for Postemployment Benefits Other Than Pensions (Employer Exposure Draft), Financial Reporting for Postemployment Benefit Plans Other Than Pension Plans (Plan Exposure Draft), and Accounting and Financial Reporting for Pensions and Financial Reporting for Pension Plans That Are Not Administered through Trusts That Meet Specified Criteria, and Amendments to Certain Provisions of GASB Statements 67 and 68 (Pension Exposure Draft). The Board’s deliberations included consideration of comment letters received in response to the Exposure Drafts and testimony provided at the public hearings.

The Board began deliberations by discussing concerns raised by respondents to the Employer, Plan, and Pension Exposure Drafts regarding the discount rate used to calculate the present value of projected benefit payments for purposes of measuring the total OPEB or pension liability. The Board tentatively concluded that the discount rate for OPEB that is provided through OPEB plans that are administered through trusts that meet the specified criteria should reflect both the long-term expected rate of return on OPEB plan investments and a liability-based rate if applicable. The Board also tentatively concluded that the final Employer and Pension Statements should carry forward the requirement to base the discount rate solely on a liability-based rate for OPEB or pensions provided through plans that are not administered through trusts that meet the specified criteria. The Board also considered a request raised by a respondent regarding whether the final Employer, Plan, and Pension Statements should be modified to allow the discount rate to be determined based on a rate no greater than the rate that is required using the current standards rather than the rate based on the proposed standards. The Board tentatively agreed that the final Employer, Plan, and Pension Statements should not include a provision that modifies the discount rate in this manner. The Board then discussed whether the final Employer and Plan Statements should include additional requirements specific to the use of the employer’s contribution policy for projecting cash flows into projected OPEB plan fiduciary net position for the determination of the discount rate. The Board tentatively agreed that these additional requirements should not be included in the final Employer and Plan Statements. The Board then discussed whether the final Employer and Plan Statements should include requirements specific to the consideration of ad hoc contributions in projecting cash flows into projected OPEB plan fiduciary net position for the determination of the discount rate. The Board tentatively agreed that requirements should not be included in the final Employer and Plan Statements about the consideration of ad hoc contributions for this purpose but that this topic should be considered for inclusion in an Implementation Guide. The Board also discussed whether the final Employer and Plan Statements should include in the discount rate provisions a specific requirement to exclude the possibility that, if all conditions are met, future benefit payments might be discounted using the long-term expected rate of return on plan investments if benefit payments in prior periods are discounted using the municipal bond index rate. The Board tentatively agreed that this specific requirement should not be included in the final Employer and Plan Statements but that it should be considered for inclusion in an Implementation Guide. The Board then discussed whether the final Employer, Plan, and Pension Statements should establish additional requirements related to the determination of the discount rate when employer contributions are made pursuant to substantially pay-as-you-go funding policies. The Board tentatively agreed not to include additional requirements related to the determination of the discount rate when employer contributions are made pursuant to substantially pay-as-you-go funding policies but to consider inclusion of this issue in an Implementation Guide. The Board also discussed whether the final Employer, Plan, and Pension Statements should establish additional requirements in relation to projecting cash outflows for benefit payments from projected fiduciary net position for determining the long-term expected rate of return when the Plan benefit terms have automatic changes, such as increases due to certain investment experience being met. The Board tentatively agreed not to include additional requirements but to instead consider inclusion of this issue in an Implementation Guide. The Board then discussed whether the final Employer and Plan Statements should be modified to include examples of alternative methods that might be appropriate to determine the sufficiency of projected OPEB plan fiduciary net position for purposes of determining the discount rate. The Board tentatively agreed that the final Employer and Plan Statements should not be modified to include such examples. The Board also discussed whether additional clarification should be included in the final Employer and Plan Statements relative to the treatment of administrative expense in the projection of cash flows for projected OPEB plan fiduciary net position for the determination of the discount rate and tentatively agreed not to include additional clarification in the Statements. The Board then discussed whether the final Employer, Plan, and Pension Statements should allow for the selection of a municipal bond rate that is not determined as of the measurement date. The Board tentatively concluded that the municipal bond rate should be determined as of the measurement date. The Board also tentatively concluded that the final Employer, Plan, and Pension Statements should carry forward the requirement to use a tax-exempt municipal bond rate for purposes of determining a single, blended discount rate. The Board also tentatively concluded that the final Employer, Plan, and Pension Statements should carry forward the requirement to use a 20-year maturity for the municipal bond rate. The Board then tentatively decided that the discussion of the discount rate in the Basis for Conclusions of the final Employer and Plan Statements should include a reference to the notion of a settlement amount as defined in Concepts Statement No. 6, Measurement of Elements of Financial Statements.

The Board then discussed certain issues related to methods of attributing costs to periods of time for purposes of measuring the total OPEB or pension liability. The Board tentatively decided to affirm that for purposes of measuring the total OPEB liability reported by employers and certain OPEB plans, the entry age actuarial cost method should be required to be used to attribute service costs to periods of employee service on an employee-by-employee basis. The Board also tentatively concludedthat, for purposes of measuring the total OPEB liability reported by employers and certain OPEB plans, the entry age actuarial cost method should determine service costs as a level percentage of pay. The Board then discussed a clarification requested by a respondent that the beginning of the attribution period should be “the first period in which the employee’s service accrues OPEB under the benefit terms, notwithstanding vesting or other similar terms.” The Board tentatively agreed to include this clarification in each final Employer and Plan Statement. The Board then discussed the proposed requirements in the Employer and Plan Exposure Drafts that, for purpose of applying the entry age actuarial cost method, the service costs of all OPEB be attributed through all assumed exit ages, through retirement. The Board tentatively concluded to affirm its proposal, but with modification to remove the phrase through retirement. The Board also tentatively concluded that for purposes of measuring the total pension liability, the entry age actuarial cost method should be required to be used to attribute service costs to periods of employee service as a level percentage of projected pay on an employee-by-employee basis, within the parameters set forth in the Pension Exposure Draft.

Next, the Board considered certain issues raised by respondents regarding the timing of the measurement of the OPEB or pension liability, the frequency of actuarial valuations, the relationship of the dates of actuarial valuations to employers’ and plans' fiscal year-ends, and the use of update procedures in lieu of obtaining new actuarial valuations. The Board tentatively concluded that the net OPEB liability disclosed by an OPEB plan in notes to the financial statements or presented in required supplementary information should be measured as of the plan’s fiscal year-end. The Board then tentatively decided to affirm its proposals in the Employer and Pension Exposure Drafts that employers be permitted to measure pension and OPEB liabilities as of a date no earlier than the end of the employer’s prior fiscal year, consistently applied from period to period, regardless of whether the OPEB or pensions are provided through plans that are administered through trusts that meet the specified criteria. The Board also tentatively agreed to clarify that the measurement date of the OPEB or pension liability should be no later than the government’s current fiscal year-end in the final Employer and Pension Statements. The Board also tentatively agreed not to include a definition of the term measurement date in the glossaries of the final Employer and Pension Statements. The Board then discussed the frequency of actuarial valuations and tentatively agreed to further consider at a subsequent meeting the potential for permitting the use of triennial actuarial valuations of OPEB (with updates) for purposes of financial reporting in limited circumstances. The Board also tentatively concluded that actuarial valuations should be performed at least biennially (with updates) for the final Pension Statement. The Board also discussed whether to carry forward the proposed actuarial valuation timing requirements for the total OPEB or pension liability reported in an employer’s financial statements to be based on an actuarial valuation no earlier than 30 months and 1 day prior to the employer’s fiscal year-end and for the total OPEB or pension liability reported in a plan’s financial statements to be based on an actuarial valuation no earlier than 24 months prior to the plan’s fiscal year-end. The Board tentatively decided to carry forward these actuarial valuation timing requirements. The Board then discussed whether the final Employer, Plan, and Pension Statements should provide additional guidance regarding what constitutes a significant change as it relates to actuarial valuation update procedures. The Board tentatively concluded that the requirements in the final Employer, Plan, and Pension Statements continue to rely on professional judgment to determine what changes are significant and that no additional guidance should be added.

Next, the Board discussed concerns raised by respondents regarding whether deviations from the Actuarial Standards of Practice are considered to be in conformity with the requirements in those Statements. The Board tentatively concluded that the final Employer, Plan, and Pension Statements should include clarification that deviations from the Actuarial Standards of Practice should not be considered to be in conformity with the final Statements and that same clarification also should be included in the final Pension Statement as an amendment to Statements 67 and 68. The Board also discussed whether the requirement for plans and employers to use the same assumptions for the same or similar measures should be reconsidered. The Board tentatively agreed to reconsider this requirement at a subsequent meeting.

The Board then discussed issues related to the recognition of changes in the OPEB and pension liability that is reported by employers other than cost-sharing employers that provide OPEB. The Board began by tentatively deciding to affirm that employers should report deferred outflows of resources and deferred inflows of resources related to (1) the effects on the measurement of the total OPEB and pension liability of differences between expected and actual experience and changes of assumptions and (2) differences between projected and actual earnings on OPEB plan investments for OPEB provided through OPEB plans that are administered through trusts that meet the specified criteria. The Board also tentatively decided to affirm that the effects of changes in an employer’s OPEB or pension liability that are reported as deferred outflows of resources or deferred inflows of resources should be recognized in expense over a closed period of (a) the average of the expected remaining service lives of employees that are provided with benefits for amounts related to differences between expected and actual experience and changes of assumptions related to the total OPEB and pension liability and (b) five years for differences between projected and actual earnings on OPEB plan investments. The Board then discussed whether illustrative disclosure examples should be added to the final Employer and Plan Statements to assist preparers in distinguishing the effects of changes in benefit terms from the effects of differences between expected and actual experience in the OPEB liability. The Board tentatively agreed not to provide illustrative disclosure examples in the final Statements but to consider this issue for inclusion in an Implementation Guide. The Board also tentatively agreed that additional guidance should not be added to the final Employer and Plan Statements regarding the effect of contributions and benefit payments on the amount of OPEB or pension expense recognized but instead that this issue should be considered for inclusion in an Implementation Guide. The Board then discussed and tentatively concluded to carry forward the requirement that administrative expense for OPEB or pensions that are provided through plans that are not administered through trusts that meet the specified criteria be reported as deferred outflows of resources if the expense is incurred subsequent to the measurement date but prior to the employer’s fiscal year-end. The Board then considered whether illustrations should be included in the final Statements to depict the application of the determination of the amounts to be presented for each of the sources of change in the OPEB or pension liability when the period between actuarial valuations is more than one year. The Board tentatively agreed not to include such illustrations in the final Statements but to instead consider inclusion of this issue in an Implementation Guide.

Minutes of Meetings, November 11-13, 2014

The Board reviewed and deliberated on issues discussed in the Exposure Drafts, Accounting and Financial Reporting for Postemployment Benefits Other Than Pensions (Employer Exposure Draft), Financial Reporting for Postemployment Benefit Plans Other Than Pension Plans (Plan Exposure Draft), and Accounting and Financial Reporting for Pensions and Financial Reporting for Pension Plans That Are Not Administered through Trusts That Meet Specified Criteria, and Amendments to Certain Provisions of GASB Statements 67 and 68 (Pension Exposure Draft). The Board’s deliberations included consideration of comment letters received in response to the Exposure Drafts and testimony provided at the public hearings.

The Board began deliberations by discussing concerns raised by respondents to the Employer and Plan Exposure Drafts regarding the timeframe in which the final Statements are scheduled to be issued. The Board tentatively decided that the project timeline for issuing the final Statements should not be extended at this time.

The Board then discussed certain issues related to the scope and applicability of the Exposure Drafts. The Board considered a question raised by a respondent regarding whether the final Employer and Pension Statements should specifically address how the involvement of a component unit that does not report under GASB standards should be viewed for purposes of applying the provisions of the Employer and Pensions Exposure Drafts. The Board tentatively decided that the final Employer and Pension Statements should not address this specific circumstance, but it concluded that this issue should be included on the list of potential items to consider in an Implementation Guide. The Board then discussed whether the scope of the Postemployment Benefits project should be expanded to reexamine the requirements of Statement No. 16, Accounting for Compensated Absences. The Board tentatively decided that the scope of the project should not be expanded to include accounting for compensated absences.

The Board discussed a clarification requested by a respondent to reiterate that healthcare benefits paid through a pension plan are required to be accounted for and reported separately from pensions. The Board tentatively decided to include this clarification in each final Statement. The Board then discussed a suggestion for clarification raised by a respondent regarding the applicability of the Employer and Pension Exposure Drafts to nonemployer contributing entities in circumstances in which the nonemployer contributing entity makes benefit payments to third-parties. The Board tentatively decided to clarify the applicability of the final Employer and Plan Statements in these circumstances. The Board also discussed a request by a respondent to identify the applicability of requirements for accounting and financial reporting by governmental nonemployer contributing entities that have a legal requirement to provide financial support directly to a postemployment benefits other than pensions (OPEB) plan that is used to provide OPEB to employees of another entity but do not meet the criteria for a special funding situation for entities participating in defined benefit OPEB plans and for entities participating in defined contribution OPEB plans. The Board tentatively concluded that the clarification should be included in the final Employer and Pension Statements.

The Board discussed whether the definition of insured plan should be included in the scope and applicability section of the final Plan Statement and tentatively concluded that the definition should be included. The Board also discussed whether benefits that are provided through plans that are administered through trusts that meet the specified criteria should continue to be separately reported from those that are not in the Employer, Plan, and Pension Exposure Drafts. The Board tentatively concluded that this approach should be maintained for each final Statement.

The Board considered certain issues raised by respondents regarding employer liability recognition. The Board discussed whether the requirements for a single or agent employer to recognize a liability for its OPEB obligation as the net OPEB liability (if provided through an OPEB plan that is administered through a trust that meets the specified criteria) or as the total OPEB liability (if provided through an OPEB plan that is not administered through such a trust) should be carried forward to the final Employer Statement. The Board tentatively decided to carry forward the provisions for recognition of a single or agent employer’s obligation for OPEB from the Employer Exposure Draft. The Board then discussed respondent requests to present an employer’s liability for OPEB as a contingent liability in the employer’s financial statements. The Board tentatively decided that an employer’s liability for OPEB should not be presented in the employer’s financial statements using the term contingent. The Board also discussed the requirement that an employer that provides pensions through a pension plan that is not administered through a trust that meets the specified criteria recognize a liability for pensions equal to the total pension liability. The Board tentatively decided to carry forward this requirement to the final Pension Statement.

The Board discussed concerns raised by respondents regarding whether the OPEB plan’s fiduciary net position component of the net OPEB liability should be determined using the same valuation methods that are required to be used by the OPEB plan for purposes of reporting the OPEB plan’s statement of fiduciary net position. The Board tentatively decided that the OPEB plan’s fiduciary net position should be determined using the same valuation methods that are required to be used by the OPEB plan for purposes of reporting the OPEB plan’s statement of fiduciary net position.

The Board then discussed issues related to the projection of benefits in the measurement of the total OPEB liability and the total pension liability. The Board began by considering whether the projection of OPEB should include taxes or other assessments on benefit payments. The Board tentatively decided to carry forward to the final Employer and Plan Statements the provision that the projection of benefit payments for purposes of measuring the total OPEB liability should incorporate the projected effects of taxes or other assessments on benefit payments.

The Board tentatively decided that the excise tax imposed as a result of the Patient Protection and Affordable Care Act should not be explicitly identified in the standards section of the Employer and Plan Statements. The Board also discussed whether projected benefit payments should be reduced for subsides expected to be received for making benefit payments other than those received for providing Medicare benefits. The Board tentatively concluded that projected benefit payments for purposes of measuring the total OPEB liability should not be reduced for amounts expected to be received for making payments other than those received for providing Medicare benefits.

The Board discussed the use of claims costs, or age-adjusted premiums approximating claims costs, to project OPEB. The Board tentatively decided that the projection of benefit payments for purposes of measuring the total OPEB liability should be based on claims costs, or age-adjusted premiums approximating claims costs. The Board also tentatively decided that the term implicit rate subsidy should not be used in the standards section of the final Employer and Plan Statements. The Board also tentatively concluded that the glossaries of the final Employer and Plan Statements should not include a definition of age-adjusted premium. As part of this discussion, the Board also considered whether to modify references to the term claims costs to retiree claims costs. The Board tentatively decided not to make this modification. The Board also tentatively decided not to include an example of what is meant by claims costs and how claims costs should be determined in the final OPEB statements but to instead include this issue on a list of items to consider in an Implementation Guide.

The Board discussed whether the final Employer and Plan Statements should carry forward the provision that the projection of benefit payments for purposes of measuring the total OPEB liability include the effects of an established pattern of practice with regard to the sharing of benefit-related costs with inactive employees. The Board tentatively decided to carry forward this provision. The Board then discussed whether to include clarification that the projection of benefit payments for purposes of measuring the total liability should not include administrative expense. The Board tentatively concluded that this clarification should be included in each final Statement. The Board also discussed whether the requirements for projection of benefit payments for purposes of measuring the total OPEB liability should include explicit references to the need to consider the trend in future healthcare costs as part of the projection of healthcare-related benefits in the final Employer and Plan Statements. The Board tentatively decided that no reference should be included.

The Board discussed a request by a respondent that the requirements for projection of benefit payments for purposes of measuring the total OPEB liability not include an assumption for the healthcare trend rate. The Board tentatively concluded that the requirements for the projection of benefit payments should include consideration of the healthcare trend rate. The Board also discussed whether the projection of benefit payments for purposes of measuring the total liability should be made in accordance with the benefit terms and any additional legal agreements to provide benefits that are in force at the measurement date. The Board tentatively concluded that this requirement should be carried forward in each final Statement. The Board then considered whether the provisions for projection of benefit payments for purposes of measuring the total liability should include the consideration of the potential future effects of limitation of resources or caps on funding. The Board tentatively decided not to include this provision in each final Statement. The Board also tentatively decided that the requirements for projection of benefit payments for purposes of measuring the total pension liability in a qualified excess benefit arrangement should not be limited to the projection of benefit payments to employees receiving benefit payments.

Minutes of Teleconference, October 20, 2014

The Board reviewed a summary of the results of the field test conducted during the comment period for the Exposure Drafts, Accounting and Financial Reporting for Postemployment Benefits Other Than Pensions, and Financial Reporting for Postemployment Benefit Plans Other Than Pension Plans. These results did not include the field test for the alternative measurement method, which will be reviewed by the Board at a future meeting.

Minutes of Meetings, September 30-October 1, 2014

The Board reviewed and deliberated on issues discussed in the Exposure Draft, Accounting and Financial Reporting for Pensions and Financial Reporting for Pension Plans That Are Not Administered through Trusts That Meet Specified Criteria, and Amendments to Certain Provisions of GASB Statements 67 and 68. (Pension Exposure Draft). The Board’s deliberations included consideration of comment letters received in response to the Pension Exposure Draft and testimony provided at the public hearings.

The Board began deliberations by discussing the overall approach taken in the Pension Exposure Draft. The Board tentatively decided that the overall approach taken, which bases the accounting and financial reporting requirements on the requirements in Statement No. 68, Accounting and Financial Reporting for Pensions, continues to be appropriate.

Next, the Board considered a respondent’s request to require information about federal Social Security coverage to be provided in a note disclosure or in required supplementary information. The Board tentatively decided that these potential disclosures are outside the scope of the Postemployment Benefit Accounting and Financial Reporting project. However, the Board agreed to add this potential disclosure to the list of potential projects as part of its technical plan.

The Board then discussed a suggestion to issue the amendments to Statement No. 67, Financial Reporting for Pension Plans, and Statement 68 separate from the requirements for pensions and pension plans not administered through trusts that meet the criteria in paragraph 4 of the Pension Exposure Draft. The Board tentatively decided to issue one final Statement that includes all of the issues that were included in the Pension Exposure Draft.

The Board concluded by discussing general structure, organization, and format comments received in regard to the Pension Exposure Draft and the Exposure Drafts, Accounting and Financial Reporting for Postemployment Benefits Other Than Pensions and Financial Reporting for Postemployment Benefit Plans Other Than Pension Plans.

Minutes of Meetings, May 28-29, 2014

The Board reviewed the ballot drafts of three proposed Statements: Accounting and Financial Reporting for Pensions and Financial Reporting for Pension Plans That Are Not Administered through Trusts That Meet Specified Criteria, and Amendments to Certain Provisions of GASB Statements 67 and 68, Financial Reporting for Postemployment Benefit Plans Other Than Pension Plans, and Accounting and Financial Reporting for Postemployment Benefits Other Than Pensions.

The Board tentatively agreed on various clarifying changes to the Exposure Drafts. Finally, the Board unanimously agreed to move forward with the issuance of the three Exposure Drafts for comment.

Minutes of Meetings, April 8-10, 2014

The Board reviewed a ballot draft of an Exposure Draft, Accounting and Financial Reporting for Pensions and Financial Reporting for Pension Plans That Are Not Administered through Trusts That Meet Specified Criteria and Amendments to Certain Provisions of GASB Statements 67 and 68, tentatively agreeing on various clarifying changes to the draft.

Minutes of Meetings, March 3-5, 2014

The Board continued its discussion of the alternative measurement method to measure postemployment benefits other than pensions (OPEB) in relation to (1) default probabilities of an employee remaining employed until the assumed retirement age to use as turnover assumptions and (2) default factors for calculating age-adjusted premiums when the same premiums are charged to active and inactive employees and the employer or plan sponsor is unable to obtain age-adjusted premium information for inactive employees from the insurer or service provider. The Board tentatively agreed that when experience data on the covered group is not available, default probabilities for the turnover assumption in applying the alternative measure should be withdrawal rates by gender, age, and years of service in the most recently available annual report of the Civil Service Retirement and Disability Fund. The Board also tentatively agreed that project staff should continue to further explore options in relation to use of default probabilities in calculating age-adjusted premiums used in applying the alternative measurement method.

Next, the Board discussed expected benefits and perceived costs from proposed standards for (1) accounting and financial reporting for OPEB, (2) financial reporting for OPEB plans, and (3) accounting and financial reporting for pensions and financial reporting for pension plans that are not administered through trusts that meet specified criteria. The Board tentatively agreed that subject to additional information that will be obtained as the result of due process, including a scheduled field test, the expected benefits of information to stakeholders from the proposed standards exceed the anticipated costs to preparers and users.

The Board then discussed potential clarifying amendments to Statements No. 67, Accounting for Pension Plans, and No. 68, Accounting and Financial Reporting for Pensions, addressing requirements related to (1) notes to required supplementary information schedules for pension plans, (2) payables to the pension plan, (3) employers that have a special funding situation and receive support from nonemployer contributing entities that are not in a specific special funding situation, and (4) revenue recognition for the support of nonemployer contributing entities that make contributions that are not legally required. The Board discussed requirements for notes to required supplementary information schedules for pension plans and determined that Statement 67 should be amended to clarify that information presented in these notes related to factors that significantly affect trends in the annual money-weighted rate of return on pension plan investments is limited to factors within the control of management. Next, the Board agreed to amend Statements 67 and 68 to remove contractually deferred contributions with separate payment schedules from the category of separately financed specific liabilities to a pension plan.

The Board also tentatively decided Statements 67 and 68 should clarify that amounts to reduce payables for contractually deferred contributions with separate payment schedules should be excluded from measures of actuarially determined contributions, contractually required contributions, and statutorily required contributions that are required to be presented in schedules of required supplementary information. The Board also tentatively decided that Statement 68 should be amended to adjust the amounts recognized as revenue and expense by an employer that has a special funding situation for a separately financed liability. For employers that provide pensions through a cost-sharing plan, the Board tentatively agreed that Statement 68 should be amended to require the employer to recognize revenue and pension expense equal to the support provided by the nonemployer contributing entity. For employers that provide pensions through single or agent employer plans, Statement 68 should be amended to require the employer to recognize revenue for the support of the nonemployer contributing entity. The Board also tentatively agreed that Statement 68 should be amended to adjust the amounts recognized as expense by each employer and nonemployer contributing entity that does not have a separately financed liability by reducing expense in an amount equal to its proportionate share of the contributions recognized by the pension plan for separately financed specific liabilities of other employers or nonemployer contributing entities. Next, the Board tentatively decided that guidance should be added to the Comprehensive Implementation Guide to clarify the accounting and financial reporting for an employer that has a special funding situation and also receives support from a nonemployer contributing entity that is not in a special funding situation. The Board also tentatively decided that Statement 68 should be amended to clarify that revenue should be recognized in the period in which the change in the net pension liability is reported for the support of nonemployer contributing entities that are not in a special funding situation, rather than in conformity with the revenue recognition requirements of Statement No. 24, Accounting and Financial Reporting for Certain Grants and Other Financial Assistance.

The Board also reviewed preballot drafts for proposed Statements on (1) accounting and financial reporting for OPEB, (2) financial reporting for OPEB plans, and (3) accounting and financial reporting for pensions and financial reporting for pension plans that are not administered through trusts that meet specified criteria. The Board tentatively agreed to various clarifying changes to the drafts and directed the project staff to prepare ballot drafts for the proposed Statements.

Minutes Archive
 

Other Postemployment Benefit Accounting and Financial Reporting—Tentative Board Decisions


These tentative decisions have been made since the issuance of the Exposure Draft Documents and in anticipation of a final Statement. The Board tentatively agreed on the following:

Project Scope
  • Potential disclosures about federal Social Security coverage should be excluded from the Postemployment Benefit Accounting and Financial Reporting project.
Pensions That Are Not Administered Through Trusts
  • The overall approach taken in the Exposure Draft, Accounting and Financial Reporting for Pensions and Financial Reporting for Pension Plans That Are Not Administered through Trusts That Meet Specified Criteria, and Amendments to Certain Provisions of GASB Statements 67 and 68 (Pension Exposure Draft), which bases the accounting and financial reporting requirements on the requirements in Statement 68, continues to be appropriate.
  1. Scope and Applicability
    • The scope should include all entities that hold employer assets that are associated with a pension plan that is not administered through a trust that meets the specified criteria.
  2. Liability Recognition and Measurement
    • An employer that provides pensions through a pension plan that is not administered through a trust that meets the specified criteria should recognize a liability equal to its total pension liability.
    • The discount rate used to calculate the present value of projected benefit payments in the measurement of the total pension liability should be based solely on a yield or index rate for 20-year, tax-exempt general obligation municipal bonds with an average rating of AA/Aa or higher determined as of the measurement date.
    • The method of attributing service costs to periods of time in the measurement of the total pension liability should use the entry age actuarial cost method as a level percentage of projected pay on an employee-by-employee basis.
    • Measurements of the total pension liability should:
      • Be based on an actuarial valuation no earlier than 30 months and 1 day prior to the employer’s fiscal year-end for an employer’s financial statements and 24 months prior to the plan’s fiscal year-end for a plan’s financial statements.
      • Rely on professional judgment to determine what constitutes a significant change as it relates to actuarial valuation update procedures.
    • The timing and frequency of the actuarial valuations should be:
      • As of a date no earlier than the end of the employer’s prior fiscal year, consistently applied from period to period, and no later than the government’s current fiscal year-end.
      • Performed at least biennially.
    • The requirements related to liabilities and expenditures related to defined benefit pensions, payables to a defined benefit pension plan, liabilities for insured benefits, and defined contribution pensions recognized in modified accrual financial statements should be carried forward to the final Pension Statement.
       
    • Special Funding Situations
      • The requirements for special funding situations in circumstances in which pensions are provided through plans that are not administered through trusts that meet the specified criteria should be carried forward to the final Pension Statement.
      • Employers should recognize revenue and expense for support provided from nonemployer contributing entities not in a special funding situation only to the extent that the nonemployer contributing entity is making benefit payments as the benefits come due.
    • Component units/fund allocation
      • The final Pension Statement should carry forward the requirement to consider a primary government and its component units to be one employer for purposes of plan type.
      • In circumstances in which a primary government and its component units provided pensions through the same single-employer or agent plan, the final Pension Statement should carry forward the requirements to:
        • Provide the same note disclosure and required supplementary information for a single employer in the reporting entity’s financial report.
        • Provide cost-sharing employer accounting and financial reporting requirements in stand-alone reports of the primary government and its component units.
      • The final Pension Statement should not provide specific guidance for allocating liabilities related to pensions among funds in the financial statements and between governmental and business-type activities in the government-wide statement of net position.
    • Insured benefits:
      • The final Pension Statement should carry forward the recognition, measurement, and disclosure requirements related to insured benefits, clarifying that the requirements related to insured benefits, clarifying that the requirements for liability and expense recognition for insured benefits relate to annual contribution or premiums requirements in accordance with the agreement with the insurance company.
  3. Recognition of Changes in the Total Pension Liability
    • The effects of differences between expected and actual experience and changes in assumptions should be reported as deferred outflows of resources or deferred inflows of resources.
    • The effects of changes in an employer’s pension liability for differences between expected and actual experience and changes of assumptions that are reported as deferred outflows of resources or deferred inflows of resources should be recognized in pension expense over a closed period representing the average of the expected remaining service lives of employees that are provided with benefits.
    • Administrative expenses for pensions should be reported as deferred outflows of resources if the expenses are incurred subsequent to the measurement date but prior to the employer’s fiscal year-end.
  4. Effective Date
    • The effective date for amendments related to Statements 67 and 68 and the requirements related to assets held for pension plans that are not administered through trusts that meet the specified criteria should be for fiscal years beginning after June 15, 2015.
    • The effective date for all other pensions provided through pension plans that are not administered through trusts that meet the specified criteria should be for fiscal years beginning after June 15, 2016.

Postemployment Benefits Other Than Pensions (OPEB)
  1. Scope and Applicability
    • The approach should be maintained to report benefits that are provided through plans that are administered through trusts that meet specified criteria separately from those that are not in the final Employer, Plan, and Pension Statements.
    • The scope of the final Plan Statement should include all entities that hold employer assets associated with OPEB that are associated with an OPEB plan that is not administered through a trust that meets the specified criteria.
  2. Liability Recognition and Measurement
    • For single or agent employers:
      • Recognition of a liability for its obligation related to OPEB should be:
        • The net OPEB obligation (the total OPEB liability less OPEB plan fiduciary net position) if provided through an OPEB plan that is administered through a trust that meets specified criteria
        • The total OPEB liability if provided through an OPEB plan that is not administered through a trust that meets the specified criteria
      • OPEB plan fiduciary net position should be determined using the same valuation methods that are required to be used by the OPEB plan for purposes of preparing the OPEB plan’s statement of fiduciary net position.
      • Projected benefit payments in the measurement of the total OPEB liability should:
        • Include the projected effects of taxes or assessments on benefit payments.
        • Not be reduced by subsidies expected to be received for making benefit payments other than those received for providing Medicare benefits.
        • Be based on claims costs, or age-adjusted premiums approximating claims costs.
        • Include the effects of an established pattern of practice with regard to the sharing of benefit-related costs with inactive employees.
        • Be made in accordance with the benefit terms and any additional legal agreements to provide benefits that are in force at the measurement date.
        • Not include consideration of the potential future effects of limitation of resources or caps on funding.
      • The discount rate used to calculate the present value of projected benefit payments in the measurement of the total OPEB liability should:
        • Reflect the long-term expected rate of return on OPEB plan investments and a liability-based rate, if applicable.
        • Be based solely on a yield or index rate for 20-year, tax-exempt general obligation municipal bonds with an average rating of AA/Aa or higher determined as of the measurement date for OPEB provided through plans that are not administered through trusts that meet the specified criteria.
      • The method of attributing service costs to periods of time in the measurement of the total OPEB liability should:
        • Use the entry age actuarial cost method as a level percentage of projected pay on an employee-by-employee basis.
        • Consider the beginning of the attribution period “the first period in which the employee’s service accrues OPEB under the benefit terms, notwithstanding vesting or other similar terms.”
        • Attribute the service costs of all OPEB through all assumed ages.
      • The net OPEB liability disclosed by an OPEB plan in notes to the financial statements or presented in RSI should be measured as of the plan’s fiscal year-end.
      • Measurements of the total OPEB liability should:
        • Be based on an actuarial valuation no earlier than 30 months and 1 day prior to the employer’s fiscal year-end for an employer’s financial statements and 24 months prior to the plan’s fiscal year-end for a plan’s financial statements.
        • Rely on professional judgment to determine what constitutes a significant change as it relates to actuarial valuation update procedures.
      • The timing and frequency of the actuarial valuations should be:
        • As of a date no earlier than the end of the employer’s prior fiscal year, consistently applied from period to period, and no later than the government’s current fiscal year-end.
        • Performed at least biennially.
        • The requirements related to liabilities and expenditures related to defined benefit OPEB, payables to a defined benefit OPEB plan, liabilities for insured benefits, and defined contribution OPEB recognized in modified accrual financial statements should be carried forward to the final Employer Statement.
    • For cost-sharing employers:
      • The requirement that a cost-sharing employer have an individual liability relative to the net OPEB liability for benefits provided through a cost-sharing OPEB plan should be carried forward to the final Employer Statement.
      • The requirement that a cost-sharing employer’s proportion be determined as the relationship of the employer’s contributions relative to the contributions of all participating employers in the cost-sharing OPEB plan on a basis consistent with the manner in which contributions to the OPEB plan are determined should be carried forward to the final Employer Statement.
      • The requirement for a cost-sharing employer to report the net effect of a change in its proportion as a deferred outflow of resources or deferred inflow of resources related to OPEB and to recognize that amount in OPEB expense over a closed period representing the average remaining service life of all employees that provided with benefits should be carried forward to the final Employer Statement.
    • For special funding situations:
      • The requirements for special funding situations in circumstances in which OPEB is provided through plans that are administered through trusts that meet the specified criteria should be carried forward to the final Employer Statement.
      • The requirements for special funding situations in circumstances in which OPEB is provided through plans that are not administered through trusts that meet the specified criteria should be carried forward to the final Employer Statement.
      • The requirements for employers to recognize revenue and expense for support provided from nonemployer contributing entities not in a special funding situation only to the extent that the nonemployer contributing entity is making benefit payments as the benefits come due should be carried forward to the final Employer Statement.
    • Alternative measurement method (AMM):
      • The use of an alternative measurement method should be permitted in place of an actuarial valuation to measure the total OPEB liability in circumstances in which OPEB is provided through plans with a small number of members.
      • The threshold to apply the alternative measurement method should be for circumstances in which fewer than 100 employees (active and inactive) are provided with OPEB through an OPEB plan.
      • The final Employer and Plan Statements should allow for an employer that does not have historic age-based turnover data to use historic based turnover data of a similar group that includes the employer’s covered group or the most recent experience of the employee group covered by the Federal Employees Retirement System as maintained by the U.S. Office of Personnel Management in measuring the total OPEB liability using the alternative measurement method.
      • The final Employer and Plan Statements should carry forward the assumptions related to the determination of per capita healthcare rates when the same premiums are charged to active employees and inactive employees and age-adjusted premium information for inactive employees is not able to be obtained from the insurer or service provider that are based on (1) claims costs increasing 4 percent per year of age until age 65, (2) claims costs increasing 3 percent per year of age after age 65, and (3) claims cost experiencing a 50 percent reduction beginning at Medicare eligibility for OPEB plans with Medicare coordination.
      • The final Employer and Plan Statements should carry forward other simplifications proposed in the Exposure Drafts.
      • Notes to the financial statement should provide that the measurements were not based on an actuarial valuation.
    • Component units/fund allocation:
      • The final Employer and Plan Statements should carry forward the requirement to consider a primary government and its components units to be one employer for purposes of plan type.
      • In circumstances in which a primary government and its component units provide OPEB through the same single-employer plan, the final Employer Statement should carry forward the requirements to:
        • Provide the same note disclosure and required supplementary information for a single employer in the reporting entity’s financial reporting.
        • Provide cost-sharing employer accounting and financial reporting requirements in stand-alone reports of the primary government and its component units.
      • The final Employer Statement should not provide specific guidance for allocating liabilities related to OPEB among funds in the financial statements and between governmental and business-type activities in the government-wide statement of net position.
    • Insured benefits:
      • The final Employer Statement should carry forward the recognition, measurement, and disclosure requirements related to insured benefits, clarifying that the requirements for liability and expense recognition for insured benefits relate to annual contribution or premiums requirements in accordance with the agreement with the insurance company.
  3. Recognition of Changes in the OPEB Liability
    • The effects of differences between expected and actual experience and changes in assumptions in the total OPEB liability should be reported as deferred outflows of resources or deferred inflows of resources.
    • For OPEB provided through OPEB plans that are administered through trusts that meet the specified criteria, the difference between projected and actual earnings on OPEB plan investments should be reported as deferred outflows of resources or deferred inflows of resources.
    • The effects of changes in an employer’s OPEB liability for differences between expected and actual experience and changes of assumptions that are reported as deferred outflows of resources or deferred inflows of resources should be recognized in OPEB expense over a closed period representing the average of the expected remaining service lives of employees that are provided with benefits.
    • The difference between projected and actual earnings on OPEB plan investments reported as deferred outflows of resources or deferred inflows of resources should be recognized in OPEB expense over a closed period of five years.
    • Administrative expenses for OPEB should be reported as deferred outflows of resources if the expenses are incurred subsequent to the measurement date but prior to the employer’s fiscal year-end.
  4. Plan Reporting Issues
    • The requirement for an OPEB plan to recognize a liability to employees for benefits to the extent that benefits are currently due and payable should be carried forward to the final Plan Statement.
    • The requirement to exclude amounts paid by inactive plan members receiving benefit payments from the amounts reported as contributions and benefit payments by an OPEB plan should be carried forward to the final Plan Statement.
  5. Effective Date
    • All OPEB plans should be required to implement the final Plan Statement at the same time.
    • All employers should be required to implement the final Employer Statement at the same time.
    • The effective date for the final Plan Statement should be for fiscal years beginning after June 15, 2016, with earlier application encouraged.
    • The effective date for the final Employer Statement should be for fiscal years beginning after June 15, 2017, with earlier application encouraged.