HomeMy WebLinkAbout10.27.22 Finance Committee Agenda PacketCity Council Finance Committee Agenda October 27, 2022
Page 1
SARATOGA CITY COUNCIL
FINANCE COMMITTEE
October 27, 2022
3:30 P.M. REGULAR MEETING
Teleconference/Public Participation Information to Mitigate the Spread of COVID-19
This meeting will be held entirely by teleconference. All members of the Committee and staff
will only participate via the Zoom platform using the process described below. The meeting is
being conducted pursuant to recent amendments to the teleconference rules required by the
Ralph M. Brown Act allowing teleconferencing during a proclaimed state of emergency when
local officials have recommended social distancing. The purpose of the amendments is to
provide the safest environment for the public, elected officials, and staff while allowing for
continued operation of the government and public participation during the COVID-19
pandemic.
Members of the public can view and participate in the meeting by:
1. Using the Zoom website https://us02web.zoom.us/j/88318587204
Webinar ID: 883 1858 7204 and raising their hand to speak on an agenda item when
directed by the Mayor.
2. Calling 1.669.900.6833 or 1.408.638.0968 and pressing *9 to raise their hand to speak on
an agenda item when directed by the Mayor.
The public will not be able to participate in the meeting in person.
Written Communication
Members of the public can send written comments prior to the meeting by commenting
online at www.saratoga.ca.us/fc prior to the start of the meeting. These emails will be
provided to the members of the Council and will become part of the official record of the
meeting.
Public Comment
Members of the public may comment on any item for up to three (3) minutes. The amount of
time for public comment may be reduced by the Mayor.
Meeting Recording Information
In accordance with the Saratoga City Council’s Meeting Recording Policy, the City
Council Finance Committee Meetings are recorded and made available to the public
following the meeting on the City website.
City Council Finance Committee Agenda October 27, 2022
Page 2
CALL TO ORDER
ROLL CALL
ORAL COMMUNICATIONS ON NON-AGENDIZED ITEMS
Any member of the public may address the Committee about any matter not on the agenda
for this meeting for up to three (3) minutes. The law generally prohibits the Committee from
discussing or taking action on such items. The Committee may choose to place the topic on a
future agenda.
AGENDA ITEMS
1. Finance Committee Minutes
Recommended Action:
Review and approve the minutes for the September 22, 2022 meeting
Finance Committee Minutes
2. Other Post-Employment Benefits (OPEBs) Actuarial Valuation Project Overview
Recommended Action:
Receive presentation from actuarial firm Foster & Foster – No action required
OPEBs Actuarial Valuation Project Overview
Attachment 1 - OPEBs and GASB 45 Q&A
Attachment 2 - What Is an Implied Subsidy
Attachment 3 - The Implied Subsidy and PEMHCA
Attachment 4 - GASB Approves New OPEB
3. Single Audit Update for the fiscal year ended June 30, 2022
Recommended Action:
Receive report – No action required
Preliminary Single Audit 2022-06-30
Attachment 1 - Schedule of Federal Awards 2021-22
Attachment 2 - Single Audit Exemption Notice
ADJOURNMENT
CERTIFICATE OF POSTING OF THE AGENDA, DISTRIBUTION OF THE AGENDA PACKET,
COMPLIANCE WITH AMERICANS WITH DISABILITIES ACT
I, Gina Scott, Administrative Analyst for the City of Saratoga, declare that the foregoing agenda
for the meeting of the City Council Finance Committee of the City of Saratoga was posted and
available for public review on October 24, 2022, at the City of Saratoga, 13777 Fruitvale Ave.,
Saratoga, CA 95070, and on the City’s website at www.saratoga.ca.us.
City Council Finance Committee Agenda October 27, 2022
Page 3
Signed this 24th day of October 2022 at Saratoga, California.
Gina Scott, Administrative Analyst
In accordance with the Ralph M. Brown Act, copies of the staff reports and other materials
provided to the Committee by City staff in connection with this agenda, copies of materials
distributed to the Committee concurrently with the posting of the agenda, and materials
distributed to the Committee by staff after the posting of the agenda are available on the City
website at www.saratoga.ca.us and are available for review in the office of the City Clerk at
13777 Fruitvale Avenue, Saratoga, California.
In compliance with the Americans with Disabilities Act and the Governor’s Executive Order, if
you need assistance to participate in this meeting, please contact the City Clerk at
bavrit@saratoga.ca.us or call 408.868.1216 as soon as possible before the meeting. The City
will use its best efforts to provide reasonable accommodations to provide as much
accessibility as possible while also maintaining public safety.
[28 CFR 35.102-35.104 ADA title II]
City Council Finance Committee Minutes – September 22, 2022
Page 1
MINUTES
SARATOGA CITY COUNCIL FINANCE COMMITTEE
REGULAR MEETING
SEPTEMBER 22, 2022
CALL TO ORDER
The meeting was called to order at 3:30 p.m. via Zoom.
ROLL CALL
Present:Mayor Tina Walia, Vice Mayor Kookie Fitzsimmons, Council Member Mary-Lynne
Bernald
Also Present:James Lindsay, City Manager
Nick Pegueros, Administrative Services Director
Debbie Pedro, Community Development Director
Crystal Bothelio, Assistant City Manager
Courtney Ramos, Matrix Consulting Group
ORAL COMMUNICATIONS ON NON-AGENDIZED ITEMS
None
AGENDA ITEMS
1. Finance Committee Minutes
Recommended Action:
Approve the minutes for the May 26, 2022, Finance Committee Regular Meeting.
FITZSIMMONS/WALIA MOVED TO APPROVE THE MINUTES FOR THE MAY 26, 2022
FINANCE COMMITTEE REGULAR MEETING. MOTION PASSED BY VERBAL ROLL CALL.
AYES: FITZSIMMONS, WALIA. NOES: NONE. ABSTAIN: NONE.
2. 2022 Comprehensive Fee Study Project Overview
Recommended Action:
Receive report – No action required
Administrative Services Director Nick Pegueros introduced the Comprehensive Fee Study Project
and Matrix Consulting Group. Courtney Ramos from Matrix Consulting Group provided an
overview of the services they will be providing.
3. 2022 Finance Committee Meeting Schedule & Topics
Recommended Action:
Administrative Services Director Nick Pegueros reviewed the Finance Committee meeting
schedule for the remainder of 2022 and requested confirmation of agenda topics and dates. The
Committee concurred with agenda topics for October and November, cancelled the November 24
th
meeting due to the Thanksgiving holiday, and scheduled a special meeting Tuesday, November
29th to receive the independent auditor’s report on the fiscal year ended June 30, 2022. The
October 27th and November 29th meetings will begin at 3:30 p.m.
4. 2023-24 Budget Indicators
Recommended Action:
Receive Report – No action required
3
City Council Finance Committee Minutes – September 22, 2022
Page 2
Administrative Services Director Nick Pegueros presented a report regarding key budget
indicators for the remainder of fiscal year 2022-23 and 2023-24.
ADJOURNMENT
FITZSIMMONS/WALIA MOVED TO ADJOURN THE MEETING AT 4:21 PM. MOTION PASSED
BY VERBAL ROLL CALL. AYES: FITZSIMMONS, WALIA. NOES: NONE.
Minutes respectfully submitted:
Gina Scott, Administrative Analyst
City of Saratoga
4
ADMINISTRATIVE SERVICES
Memorandum
To:City Council Finance Committee
From:Nick Pegueros
Date:October 27, 2022
Subject:Other Post-Employment Benefits (OPEBs) Actuarial Valuation Project Overview
Other Post-Employment Benefits (OPEBs) are those benefits provided to retirees, other than pensions,
regardless of savings accumulated to fund the benefit. Saratoga provides one OPEB, retiree medical,
as required by the City’s contract with CalPERS Medical under the Public Employees’ Medical and
Hospital Care Act (PEMHCA). While the annual cost of this benefit is modest at $1,812 for 2023, the
benefit presents an unknown liability for the City.
The Governmental Accounting Standards Board (GASB) issued Statement Numbers 43 and 45 (GASB
43/45) in 2004, requiring that governmental entities report the assets, liabilities, and net assets of
OPEBs. Attachment 1 provides a brief overview of OPEB terminology. In 2015, GASB superseded
earlier OPEB reporting requirements with Statement Numbers 74 and 75 (GASB 74/75). A key element
of GASB 74/75 is guidance on implied subsidies inherent in certain medical plan structures, such as
the requirement in PEMHCA to provide a retiree medical benefit. Attachments 2, 3, and 4 provide an
overview of implied subsidies and GASB 74/75, respectively. Saratoga determined that the liability
created by the City’s retiree medical benefit, in both iterations of OPEBs reporting requirements, is
immaterial and, therefore, not subject to reporting requirements.
We have engaged the actuarial firm Foster and Foster (formerly Bartel Associates) to conduct a GASB-
compliant actuarial valuation necessary to verify our longstanding finding that the City’s retiree
medical benefit is immaterial. It should be noted that many agencies with similar benefit structures to
Saratoga implemented the GASB 43/45 and GASB 74/75. We anticipate beginning the project after
completing the Annual Comprehensive Financial Report in December. Foster & Foster will provide
the Finance Committee an overview of GASB 75 and the project scope.
Attachments
1. OPEBs and GASB 45 –A Question & Answer Guide, by the State Treasurer Office and the California
Debt and Investment Advisory Commission (CDIAC)
2. What Is an Implied Subsidy and Why Does It Matter? by Bartel Associates (now Foster & Foster)
3. The Implied Subsidy and PEMHCA, by Bartel Associates (now Foster & Foster)
4. GASB Approves New OPEB Employer Accounting Standard (No. 75), by Bartel Associates (now
Foster & Foster)
5
C
a
l
i
f
o
r
n
i
a
D
e
b
t
a
n
d
I
n
v
e
s
t
m
e
n
t
A
d
v
i
s
o
r
y
C
o
m
m
i
s
s
i
o
n
C
D
I
A
C
#
0
6
-
0
9
45A Question and Answer Guide
GASBOPEBs &
6
For additional information or questions contact:
California Debt and Investment Advisory Commission
915 Capitol Mall, Room 400, Sacramento, CA 95814
p|916.653.3269 w|www.treasurer.ca.gov/cdiac
De
s
i
g
n
e
d
&
P
r
i
n
t
e
d
:
O
S
P
D
e
s
i
g
n
U
n
i
t
,
T
h
e
O
f
f
i
c
e
o
f
S
t
a
t
e
P
u
b
l
i
s
h
i
n
g
OS
P
0
6
9
9
1
9
5
GASBOPEBs &
45C
a
l
i
f
o
r
n
i
a
D
e
b
t
a
n
d
I
n
v
e
s
t
m
e
n
t
A
d
v
i
s
o
r
y
C
o
m
m
i
s
s
i
o
n
C
D
I
A
C
#
0
6
-
0
9
A Question and Answer Guide
GASBOPEBs &
OPEBs & GASB 45:
What are OPEBs?
OPEBs provided to retirees, spouses, and
their dependents, generally include:
• Medical benefits
• Dental benefits • Vision-care benefits
• Prescription medicine benefits
• Life insurance benefits
• Disability insurance benefits
• Group legal coverage benefits
• Long-term health care benefits
• Other health benefits – if not part
of a pension plan
What are not OPEBs?
OPEBs generally do not include:
• Pension income benefits • Sabbaticals
• Vacation benefits • Sick leave benefits
• Consolidated Omnibus Budget Reconcilia-
tion Act (COBRA) benefits
• Special termination benefits (unless the
effect is an increase in benefits that are OPEBs)
Should a public agency do anything before the GASB 45
effective date?
If the public agency is concerned about the impact on financial
reports or the potential reaction of the financial community,
a preliminary liability and expense analysis performed well in
advance of the effective date may assist in addressing this con-
cern. These amounts will need to be disclosed in connection
with the public agency’s note or bond offerings. A preliminary
liability and expense analysis might allow the agency to be bet-
ter equipped to understand and manage its OPEB obligations in
advance of its financial statement disclosure deadlines.
What method is currently used in the public agency to account
for the cost of benefits for retired employees?
Generally, most public agencies have been using a “pay-as-you-
go” method of expensing retiree benefits and have not reported
them as liabilities on their financial statements. GASB 45 will
require public agencies to account for OPEBs as liabilities, and
report them on their financial statements as the obligations
accrue, regardless of how the agencies elect to budget and pay
for these obligations.
One significant fiscal challenge facing many state and local
governments is funding and accounting for other post-em-
ployment benefits (OPEBs) for current and retired employ-
ees, particularly in light of Governmental Accounting Standards Board
(GASB) Statement Number 45 (known as “GASB 45”). Typically, public
agencies have reported the cost of retiree heath care and other non-
pension benefits on a “pay-as-you-go” basis. The annual cash paid
for benefits has been the annual expense with no other liabilities or
funding requirements reported. GASB states that the current “pay-as-
you-go” method does not accurately reflect the true costs that govern-
ments are accumulating for future benefits of current employees. Ac-
cording to GASB, the promise of future benefit is an expense that must
be recorded rather than deferred as a liability to a future generation.
What is GASB 45?
GASB’s new accounting standards for OPEBs, GASB 45, applies to all
public agencies (e.g., state governments, county and city governments,
school districts) that follow generally accepted accounting principles
(GAAP) in filing their annual financial statements and offer post-employ-
ment benefits other than pensions. Under GASB 45, public agencies
must account for, and report, the annual required contribution (ARC)
for OPEBs in the same way they report pension benefits. As a result,
the annual OPEB expense to be reported by most employers will need
to be based on actuarially determined amounts rather than on the
“pay-as-you-go” method. Governments must use actuarial evaluations
to determine the final accounting and reporting amounts expected in
the future. OPEB costs also must be reported over the working lifetime
of employees, and the information provided in financial statements
must include the funding, costs and provisions in an OPEB plan. While
GASB 45 does not require that OPEB plans be funded, it requires dis-
closure of net OPEB obligations (NOO).
GASB 45 Implementation
Implementation of GASB 45 will be in three phases: public agencies with
revenues of $100 million or more per year must comply with GASB 45
beginning the fiscal year after December 15, 2006, those with revenues
of $10 million to $100 million must comply beginning the fiscal year after
December 15, 2007, and those with revenues of less than $10 million
must comply beginning the fiscal year after December 15, 2008.
With theses dates approaching, CDIAC has compiled this Guide to
address some basic questions regarding GASB 45 implementation.
Because GASB 45 will require public agencies to disclose the NOO on
their financial statements, public agencies need to address questions
regarding the handling of any net OPEB obligations. This Guide compiles
basic information on options for addressing OPEB liabilities.1 In addi-
tion, the Guide concludes with a list of sources used as the basis for
much of the information found in this document.
A Question and Answer Guide
1 CDIAC does not specifically endorse any of the options contained in this
publication; it encourages public agencies to consult with their legal counsel
before pursuing any of the options identified.
• Lower long-term costs of OPEBs (while debt service funding may be
higher than pay-as-you-go funding in the early years, debt service fund-
ing will be predictable, while required “pay-as-you-go” funding costs
may rise unexpectedly in the future).
Disadvantages. Disadvantages to issuing an OPEB bond may include:
• Concentration of investment risk (may result due to lump sum contribu-
tion from bond proceeds as compared to spreading the investment risk
(e.g., “dollar cost averaging”) by making ARC deposits over time).
• Potential negative arbitrage (could occur if unfavorable market condi-
tions develop such that returns consistently fall below cost of funds).
• Replacement of a theoretically negotiable OPEB obligation with an ab-
solute bond obligation.
Sources Used in this Guide:
Governmental Accounting Standards
Board. Accounting and Financial Report-
ing by Employers for Postemployment
Benefits Other Than Pensions (2004).
Governmental Accounting Standards
Board. GASB Implementation Guide:
Statements 43 and 45 Questions and
Answers (2005).
Governmental Accounting Standards
Board. What Else You Should Know
about a Government’s Finances: A
Guide to Notes to the Financial
Statements and Supporting Information
(2005).
Orrick, Herrington & Sutcliffe LLP. Other
Post-Employment Benefits - The Next
Big Financial, Disclosure, Accounting
and Public Relations Challenge
Affecting State and Local Governments
(2006).
Washington Research Council. Policy
Brief PB06-14: Fully Recognizing the
Benefits of Retirement (2006).
Resources for Further Information:
Fitch Ratings. The Not So Golden Years
(Credit Implications of GASB 45) (2005).
Governmental Accounting Standards Board.
GASB Statement 45 on OPEB Accounting by
Governments: A Few Basic Questions and
Answers (in GASB: OPEB Fact Sheet) (2006).
Government Finance Officers Association.
Dispelling OPEB ‘Urban Legends’ (in
Government Finance Review) (2006).
Milliman Consultants and Actuaries.
Managing OPEB Costs under New GASB
Rules (in PERiScope) (2005).
National Association of State Auditors,
Comptrollers, and Treasurers. Preparing for
the OPEB Tsunami (2006).
National Education Association. Defending
Retiree Health Care Benefits: An NEA Guide
to Understanding and Preparing for the New
GASB Standards (2006).
Standard and Poor’s. Reporting & Credit
Implications of GASB 45 Statement on Other
Postemployment Benefits (2004).
Acknowledgements:
CDIAC thanks Barbara Lloyd (Lehman
Brothers), Jenna Magan (Orrick,
Herrington & Sutcliffe LLP), Lee Squire
(City of Brea) and Christine M. Vuletich
(City of South Lake Tahoe) for their
comments.7
questions & answers
5 This question addresses methods of meeting whatever OPEB liabilities exist, as deter-
mined by the public agency. It does not address what legal obligations exist, nor does it
address whether or how a public agency might consider modifying existing OPEB plans
or practices. There remain divergent views about the nature and extent of public agen-
cies’ obligations to maintain OPEB benefits. Circumstances are unique for each public
agency, and such questions likely would require consultation with legal counsel and
possibly negotiation and agreement among representatives from all affected parties.
6 See Orrick Herrington & Sutcliffe, LLP, Other Post-Employment Benefits—The Next Big
Financial, Disclosure, Accounting and Public Relations Challenge Affecting State and Lo-
cal Governments (2006).
7 See Orrick Herrington & Sutcliffe, Other Post-Employment Benefits—The Next Big Financial,
Disclosure, Accounting and Public Relations Challenge Affecting State and Local Govern-
ments (2006) for a discussion of some of these points.
What information is required to be reported under GASB 45?
GASB 45 requires that organizations calculate and record the
expense of their OPEB plans. These required calculations include the
determination of the ARC and the NOO.
According to GASB, the ARC is the “annual required contribution” or
the employer’s required contribution for the year, calculated in
accordance with certain parameters.
• The ARC is the sum of the “normal cost” (the portion of the pres-
ent value of estimated total benefits that is attributed to services
received in the current year) and the amortized unfunded actuari-
al accrued liability (UAAL)2 (the cost of those same employees for
past, unfunded years of service). The ARC, in effect, recognizes
that retiree health benefits are “earned” and are financial obliga-
tions accrued during an employee’s entire period of service.3
The NOO is based on the difference between the ARC and the amount
actually contributed.
• The NOO is calculated annually and changes are based on the
accumulated contributions and the accumulated ARC. At the end
of the year, the NOO equals the summation of beginning of the
year NOO, the annual OPEB cost, and the actual contribution. If
the accumulated contributions:
1) Equal the accumulated ARC, then NOO is zero (this would im-
ply that the plan is starting to be pre-funded).
2) Are greater than the accumulated ARC, then NOO is less than
zero, creating an asset on the books of the government.
3) Are less than the accumulated ARC, then NOO is greater than
zero, creating a reportable liability for GASB 45 purposes.
Note: GASB 45 will only recognize an employer contribution if it is deposited into a
GASB 45 qualified trust or equivalent arrangement.
How can an agency determine its OPEB liability?
To estimate the liability of retiree OPEB benefits, public agencies
should have an actuarial valuation performed. Under GASB 45, an
actuarial valuation generally will be needed every two or three years,
depending on the number of plan participants.
Is an actuarial valuation necessary under GASB 45?
An actuarial valuation is generally required for all plans having at least
one participating employer with more than 100 members (including
employees in active service, terminated employees who have accu-
mulated benefits but are not yet receiving them, and retirees and
beneficiaries currently receiving benefits).
What actuarial methods are available?
GASB 45 permits a choice of six actuarial cost methods to deter-
mine the annual expense. According to GASB, demographics, the level
and amount of OPEBs, and the funding status of the plan generally
influence the actuarial method chosen. The public agency’s actuary
will review these factors and recommend the best method given the
agency’s particular situation. In practice, many actuaries prefer to use
the “unit credit” actuarial cost method, under which an employee is
assumed to earn a unit benefit for each year employed, with all ben-
efits assumed accrued upon retirement.4
What options other than modifications to existing plans does a public
agency have for funding its OPEB liabilities?5
• Continue “Pay-As-You-Go” Funding. While making annual payments
towards annual OPEB costs is the simplest method in the short run,
the “pay-as-you-go” method in the long run may result in annually
increasing NOO for GASB 45 reporting purposes. This may occur
because the investment return assumptions used in the OPEB cal-
culation for the “pay-as-you-go” method likely will be based on the
public agency’s general operating fund investments, which usually
are based on a shorter investment horizon (and thereby, generally
lower rates of return) than the investment horizon for certain trust
funds (see below).
• Pre-funding OPEB Liability. Pre-funding an account (e.g., making
annual payments consistent with the ARC) can allow the public
agency to allocate funds for the express purpose of funding future
OPEB costs. The investment returns can be used to reduce the ARC
and can result in lower long-term costs. Pre-funding amounts may
be deposited in either:
1) Dedicated Fund. This fund is a separate fund set up within
the public agency’s treasury. However, in order for funds to be
counted towards the ARC for GASB 45 purposes, they must
meet certain conditions (see answer to the question “What are
the basic features of an OPEB trust?”). Therefore, revenues de-
posited in internal funds will still be treated as “pay-as-you-go”
funding for GASB 45 accounting purposes.
2) Trust Fund. GASB 45 does not require liabilities to be funded
through an irrevocable contribution; however, the rules applied
under GASB 45 make the use of an irrevocable trust beneficial
to the public agency (see below for more information on OPEB
trusts). These trusts may be funded through various means (see
below for examples of funding sources).
What are the basic features of an OPEB trust?
In order for a trust to be properly structured to fund OPEBs for GASB 45
reporting purposes, it should have the following features:
• Tax Exemption. Investment trust assets must be held by a tax-exempt
entity so that contributions may not be considered as income to the
employee or retiree under federal and state income tax laws. Also,
income on investment of trust assets must be exempt from taxation.
• Meet the Requirements of GASB 45. Contributions must be irrevocable,
protected from creditors, and limited to the funding of benefits to
retirees, spouses, and their dependants as specified in the public
agency’s OPEB plan.
• Investment in a Wider Variety of Securities. Many public agencies are
restricted by state law and the California Constitution to a narrow
range of low-risk, primarily short-term, fixed-income investments for
their operating funds. OPEB trusts should be structured to allow in-
vestment in long-term securities, such as equities, that match the
long-term nature of the obligations and therefore may provide higher
investment returns over the life of the trust.
What types of OPEB trusts are available?
There are multiple categories of OPEB trusts:
• A Section 401(h) account is a separate account established within a
qualified pension plan dedicated to pay health benefits for retirees,
spouses and their dependents. Contributions to the account may not
exceed 25 percent of total pension contributions after the date on
which the account is established.
• A Section 115 trust is considered exempt from federal income tax
either because it is an “integral part” of a single governmental
entity or because it serves an “essential governmental function” of
one or more governmental entities.
• A Section 501(c)(9) trust is considered exempt from federal income
tax. Also known as Voluntary Employees’ Beneficiary Associations,
these are separate trusts designed specifically to pay OPEB benefits.
What are the potential funding sources for OPEB obligations?
Categories of potential funding sources for OPEB obligations include, but
are not limited to, the following:
• General Fund and Reserve Funds. If a public agency decides to set aside
revenues for OPEB funding, various existing revenue sources may be
used to fund the costs.
• OPEB Bonds. See details below.
• Medicare Part D Subsidies. Qualifying em-
ployers who continue to provide prescrip-
tion drug coverage to Medicare beneficia-
ries receive a 28 percent federal govern-
ment subsidy if their employer sponsored
health care benefit plan provides cover-
age that is equivalent to that provided
under Medicare. Employers may choose
to dedicate subsidy proceeds to pay for
broader retiree health care costs.
What is an OPEB bond?
Legal authority for OPEB bonds will vary from
entity to entity within a state.6 For some pub-
lic agencies, OPEB bonds may generally be
structured like pension obligation bonds.
That is, they may be issued, depending on
the public agency, as a federally taxable bond
to refund an existing obligation such as an
OPEB unfunded liability. In such cases, the
bonds would be issued with the expectation
that the bond proceeds will be invested at a rate of return that exceeds the
total cost of borrowing. The desired result is that the transaction reduces
the public agency’s total OPEB costs, such that total debt service plus any
remaining ARC is less than the total payments that would have existed if
the bonds were not issued. By applying the higher interest rate assumption
to the increased amount invested, a public agency may reduce the overall
amount of its UAAL and ARC.
What are the advantages/disadvantages to issuing an OPEB bond?
Advantages. Advantages to issuing an OPEB bond may include:7
• Interest rate savings (bond interest costs may be less compared to the
investment return assumption used in calculating the UAAL and ARC).
• Investment earnings (rate of return may exceed the yield on the bonds
generating higher net income).
• Possible budget relief as compared to “pay-as-you-go” funding (debt
service can be tailored to meet budget targets).
• Positive overall credit rating implications (because the OPEB liability is
being addressed proactively).
• Reduced UAAL and ARC (achieved through higher investment return
expectations).
2 The UAAL will likely appear as a footnote to the financial statements.
3 & 4 See GASB, GASB Implementation Guide: Statements 43 and 45 Questions and
Answers (2005).8
questions & answers
5 This question addresses methods of meeting whatever OPEB liabilities exist, as deter-
mined by the public agency. It does not address what legal obligations exist, nor does it
address whether or how a public agency might consider modifying existing OPEB plans
or practices. There remain divergent views about the nature and extent of public agen-
cies’ obligations to maintain OPEB benefits. Circumstances are unique for each public
agency, and such questions likely would require consultation with legal counsel and
possibly negotiation and agreement among representatives from all affected parties.
6 See Orrick Herrington & Sutcliffe, LLP, Other Post-Employment Benefits—The Next Big
Financial, Disclosure, Accounting and Public Relations Challenge Affecting State and Lo-
cal Governments (2006).
7 See Orrick Herrington & Sutcliffe, Other Post-Employment Benefits—The Next Big Financial,
Disclosure, Accounting and Public Relations Challenge Affecting State and Local Govern-
ments (2006) for a discussion of some of these points.
What information is required to be reported under GASB 45?
GASB 45 requires that organizations calculate and record the
expense of their OPEB plans. These required calculations include the
determination of the ARC and the NOO.
According to GASB, the ARC is the “annual required contribution” or
the employer’s required contribution for the year, calculated in
accordance with certain parameters.
• The ARC is the sum of the “normal cost” (the portion of the pres-
ent value of estimated total benefits that is attributed to services
received in the current year) and the amortized unfunded actuari-
al accrued liability (UAAL)2 (the cost of those same employees for
past, unfunded years of service). The ARC, in effect, recognizes
that retiree health benefits are “earned” and are financial obliga-
tions accrued during an employee’s entire period of service.3
The NOO is based on the difference between the ARC and the amount
actually contributed.
• The NOO is calculated annually and changes are based on the
accumulated contributions and the accumulated ARC. At the end
of the year, the NOO equals the summation of beginning of the
year NOO, the annual OPEB cost, and the actual contribution. If
the accumulated contributions:
1) Equal the accumulated ARC, then NOO is zero (this would im-
ply that the plan is starting to be pre-funded).
2) Are greater than the accumulated ARC, then NOO is less than
zero, creating an asset on the books of the government.
3) Are less than the accumulated ARC, then NOO is greater than
zero, creating a reportable liability for GASB 45 purposes.
Note: GASB 45 will only recognize an employer contribution if it is deposited into a
GASB 45 qualified trust or equivalent arrangement.
How can an agency determine its OPEB liability?
To estimate the liability of retiree OPEB benefits, public agencies
should have an actuarial valuation performed. Under GASB 45, an
actuarial valuation generally will be needed every two or three years,
depending on the number of plan participants.
Is an actuarial valuation necessary under GASB 45?
An actuarial valuation is generally required for all plans having at least
one participating employer with more than 100 members (including
employees in active service, terminated employees who have accu-
mulated benefits but are not yet receiving them, and retirees and
beneficiaries currently receiving benefits).
What actuarial methods are available?
GASB 45 permits a choice of six actuarial cost methods to deter-
mine the annual expense. According to GASB, demographics, the level
and amount of OPEBs, and the funding status of the plan generally
influence the actuarial method chosen. The public agency’s actuary
will review these factors and recommend the best method given the
agency’s particular situation. In practice, many actuaries prefer to use
the “unit credit” actuarial cost method, under which an employee is
assumed to earn a unit benefit for each year employed, with all ben-
efits assumed accrued upon retirement.4
What options other than modifications to existing plans does a public
agency have for funding its OPEB liabilities?5
• Continue “Pay-As-You-Go” Funding. While making annual payments
towards annual OPEB costs is the simplest method in the short run,
the “pay-as-you-go” method in the long run may result in annually
increasing NOO for GASB 45 reporting purposes. This may occur
because the investment return assumptions used in the OPEB cal-
culation for the “pay-as-you-go” method likely will be based on the
public agency’s general operating fund investments, which usually
are based on a shorter investment horizon (and thereby, generally
lower rates of return) than the investment horizon for certain trust
funds (see below).
• Pre-funding OPEB Liability. Pre-funding an account (e.g., making
annual payments consistent with the ARC) can allow the public
agency to allocate funds for the express purpose of funding future
OPEB costs. The investment returns can be used to reduce the ARC
and can result in lower long-term costs. Pre-funding amounts may
be deposited in either:
1) Dedicated Fund. This fund is a separate fund set up within
the public agency’s treasury. However, in order for funds to be
counted towards the ARC for GASB 45 purposes, they must
meet certain conditions (see answer to the question “What are
the basic features of an OPEB trust?”). Therefore, revenues de-
posited in internal funds will still be treated as “pay-as-you-go”
funding for GASB 45 accounting purposes.
2) Trust Fund. GASB 45 does not require liabilities to be funded
through an irrevocable contribution; however, the rules applied
under GASB 45 make the use of an irrevocable trust beneficial
to the public agency (see below for more information on OPEB
trusts). These trusts may be funded through various means (see
below for examples of funding sources).
What are the basic features of an OPEB trust?
In order for a trust to be properly structured to fund OPEBs for GASB 45
reporting purposes, it should have the following features:
• Tax Exemption. Investment trust assets must be held by a tax-exempt
entity so that contributions may not be considered as income to the
employee or retiree under federal and state income tax laws. Also,
income on investment of trust assets must be exempt from taxation.
• Meet the Requirements of GASB 45. Contributions must be irrevocable,
protected from creditors, and limited to the funding of benefits to
retirees, spouses, and their dependants as specified in the public
agency’s OPEB plan.
• Investment in a Wider Variety of Securities. Many public agencies are
restricted by state law and the California Constitution to a narrow
range of low-risk, primarily short-term, fixed-income investments for
their operating funds. OPEB trusts should be structured to allow in-
vestment in long-term securities, such as equities, that match the
long-term nature of the obligations and therefore may provide higher
investment returns over the life of the trust.
What types of OPEB trusts are available?
There are multiple categories of OPEB trusts:
• A Section 401(h) account is a separate account established within a
qualified pension plan dedicated to pay health benefits for retirees,
spouses and their dependents. Contributions to the account may not
exceed 25 percent of total pension contributions after the date on
which the account is established.
• A Section 115 trust is considered exempt from federal income tax
either because it is an “integral part” of a single governmental
entity or because it serves an “essential governmental function” of
one or more governmental entities.
• A Section 501(c)(9) trust is considered exempt from federal income
tax. Also known as Voluntary Employees’ Beneficiary Associations,
these are separate trusts designed specifically to pay OPEB benefits.
What are the potential funding sources for OPEB obligations?
Categories of potential funding sources for OPEB obligations include, but
are not limited to, the following:
• General Fund and Reserve Funds. If a public agency decides to set aside
revenues for OPEB funding, various existing revenue sources may be
used to fund the costs.
• OPEB Bonds. See details below.
• Medicare Part D Subsidies. Qualifying em-
ployers who continue to provide prescrip-
tion drug coverage to Medicare beneficia-
ries receive a 28 percent federal govern-
ment subsidy if their employer sponsored
health care benefit plan provides cover-
age that is equivalent to that provided
under Medicare. Employers may choose
to dedicate subsidy proceeds to pay for
broader retiree health care costs.
What is an OPEB bond?
Legal authority for OPEB bonds will vary from
entity to entity within a state.6 For some pub-
lic agencies, OPEB bonds may generally be
structured like pension obligation bonds.
That is, they may be issued, depending on
the public agency, as a federally taxable bond
to refund an existing obligation such as an
OPEB unfunded liability. In such cases, the
bonds would be issued with the expectation
that the bond proceeds will be invested at a rate of return that exceeds the
total cost of borrowing. The desired result is that the transaction reduces
the public agency’s total OPEB costs, such that total debt service plus any
remaining ARC is less than the total payments that would have existed if
the bonds were not issued. By applying the higher interest rate assumption
to the increased amount invested, a public agency may reduce the overall
amount of its UAAL and ARC.
What are the advantages/disadvantages to issuing an OPEB bond?
Advantages. Advantages to issuing an OPEB bond may include:7
• Interest rate savings (bond interest costs may be less compared to the
investment return assumption used in calculating the UAAL and ARC).
• Investment earnings (rate of return may exceed the yield on the bonds
generating higher net income).
• Possible budget relief as compared to “pay-as-you-go” funding (debt
service can be tailored to meet budget targets).
• Positive overall credit rating implications (because the OPEB liability is
being addressed proactively).
• Reduced UAAL and ARC (achieved through higher investment return
expectations).
2 The UAAL will likely appear as a footnote to the financial statements.
3 & 4 See GASB, GASB Implementation Guide: Statements 43 and 45 Questions and
Answers (2005).9
For additional information or questions contact:
California Debt and Investment Advisory Commission
915 Capitol Mall, Room 400, Sacramento, CA 95814
p|916.653.3269 w|www.treasurer.ca.gov/cdiac
De
s
i
g
n
e
d
&
P
r
i
n
t
e
d
:
O
S
P
D
e
s
i
g
n
U
n
i
t
,
T
h
e
O
f
f
i
c
e
o
f
S
t
a
t
e
P
u
b
l
i
s
h
i
n
g
OS
P
0
6
9
9
1
9
5
GASBOPEBs &
• Lower long-term costs of OPEBs (while debt service funding may be
higher than pay-as-you-go funding in the early years, debt service fund-
ing will be predictable, while required “pay-as-you-go” funding costs
may rise unexpectedly in the future).
Disadvantages. Disadvantages to issuing an OPEB bond may include:
• Concentration of investment risk (may result due to lump sum contribu-
tion from bond proceeds as compared to spreading the investment risk
(e.g., “dollar cost averaging”) by making ARC deposits over time).
• Potential negative arbitrage (could occur if unfavorable market condi-
tions develop such that returns consistently fall below cost of funds).
• Replacement of a theoretically negotiable OPEB obligation with an ab-
solute bond obligation.
Sources Used in this Guide:
Governmental Accounting Standards
Board. Accounting and Financial Report-
ing by Employers for Postemployment
Benefits Other Than Pensions (2004).
Governmental Accounting Standards
Board. GASB Implementation Guide:
Statements 43 and 45 Questions and
Answers (2005).
Governmental Accounting Standards
Board. What Else You Should Know
about a Government’s Finances: A
Guide to Notes to the Financial
Statements and Supporting Information
(2005).
Orrick, Herrington & Sutcliffe LLP. Other
Post-Employment Benefits - The Next
Big Financial, Disclosure, Accounting
and Public Relations Challenge
Affecting State and Local Governments
(2006).
Washington Research Council. Policy
Brief PB06-14: Fully Recognizing the
Benefits of Retirement (2006).
Resources for Further Information:
Fitch Ratings. The Not So Golden Years
(Credit Implications of GASB 45) (2005).
Governmental Accounting Standards Board.
GASB Statement 45 on OPEB Accounting by
Governments: A Few Basic Questions and
Answers (in GASB: OPEB Fact Sheet) (2006).
Government Finance Officers Association.
Dispelling OPEB ‘Urban Legends’ (in
Government Finance Review) (2006).
Milliman Consultants and Actuaries.
Managing OPEB Costs under New GASB
Rules (in PERiScope) (2005).
National Association of State Auditors,
Comptrollers, and Treasurers. Preparing for
the OPEB Tsunami (2006).
National Education Association. Defending
Retiree Health Care Benefits: An NEA Guide
to Understanding and Preparing for the New
GASB Standards (2006).
Standard and Poor’s. Reporting & Credit
Implications of GASB 45 Statement on Other
Postemployment Benefits (2004).
Acknowledgements:
CDIAC thanks Barbara Lloyd (Lehman
Brothers), Jenna Magan (Orrick,
Herrington & Sutcliffe LLP), Lee Squire
(City of Brea) and Christine M. Vuletich
(City of South Lake Tahoe) for their
comments.10
411 Borel Avenue, Suite 101 San Mateo, California 94402
main: 650/377-1600 fax: 650/345-8057 web: www.bartel-associates.com
Copyright 2013 October 2013
What Is an Implied Subsidy and Why Does It Matter?
Before GASB 45, medical costs were accounted for as benefits were paid, known as “pay-as-you-go”
or “pay-go.” GASB 45 mandated separate accounting for retirees including accruing for future
benefits while retirees are still working. Retiree benefits are analyzed on their own for GASB
valuations: There are no active benefits to balance retirees’ excess of claims over premiums. Implied
Subsidy refers to this excess.
If your agency provides retiree healthcare (OPEB) benefits through CalPERS health plans (PEMHCA),
GASB will require recognition of the Implied Subsidy. It will almost certainly increase your
GASB 45 OPEB liability – for some agencies very significantly.
Blended Premiums Create Implied Subsidy
Studies show that healthcare costs generally increase with
age. On average, younger people are relatively healthy,
while older people have more and costlier health
expenses. The chart’s blue line shows a typical claim
curve – the healthcare cost at each age.
CalPERS, in PEMHCA, blends active employees with
pre-Medicare retirees and charges them the same medical
premium. This is the red line on the chart. The premium is
set so that total premiums paid will equal total medical
claims. However, younger employees on average are
charged a premium higher than their claims – subsidizing
older employees who, on average, have higher claims
than premiums.
Notice that the Implied Subsidy is the difference between average retiree claims and premiums
charged by the insurer or by CalPERS. For PEMHCA, the Implied Subsidy at each age will be the
same for everyone in the same plan. It does not depend on the employer-paid cash subsidy; it will be
the same amount for an employer phasing into the PEMHCA minimum as for an agency paying the
full family premium. But, since the OPEB actuarial accrued liability is much smaller for an agency
providing only PEMHCA minimum benefits, the Implied Subsidy will represent a much greater
percentage increase.
Why Is GASB Requiring This Change and When Will It Be Effective?
GASB has always deferred to actuarial standards of practice to determine how actuarial accrued
liability should be calculated. Until now, those standards have said the implied subsidy need not be
taken into account in large “community-rated” plans such as PEMHCA, where each agency is a small
part of the total pool whose demographics will not affect premium. Proposed new actuarial standards
require Implied Subsidy inclusion in all cases. The standards are not expected to change materially
before being finalized in the coming year, when they will become effective for all GASB OPEB
valuations.
11
June 2015
411 Borel Avenue, Suite 101 y San Mateo, California 94402
main: 650/377-1600 y fax: 650/345-8057 y web: www.bartel-associates.com
Copyright 2015
The Implied Subsidy and PEMHCA
If Your Agency Provides Retiree Healthcare Benefits Through PEMHCA,
GASB 45 Will Require Recognition of the Implied Subsidy
Definition
In PEMHCA1, the implied subsidy is the benefit retirees derive from paying the same premiums as active
employees. Because younger people are generally healthier than older people, retirees on average have
higher health expenses than employees. This results in an (implied) active premium payment which
subsidizes the cost for older retirees (subsidy).
Example
Suppose an agency has 1 employee (age 40) and 1 retiree (age 60) each with a $600 monthly premium, and
the agency pays the full premium for both. For simplicity, assume the employee’s expected medical
claims2 are $500 and the retiree’s expected medical claims are $700. Here’s how premiums are used to
actually provide benefits:
Premiums PEMHCA Expected Claims
$600 Active
$1,200
$500 Active
$700 Retiree $600 Retiree
The agency paid $600 for the retiree, and PEMHCA used this payment plus $100 of the active premium to
cover the retiree’s $700 expected claims. The implied subsidy is $100. Including the implied subsidy simply
means replacing premiums paid with expected claims. In other words, the agency should consider their
payment to PEMHCA as $500 for the active employee and $700 for the retiree.
Common Questions
The following responses are based on the above example:
Why was it not included in past valuations, but will be included in future valuations?
GASB 453 states that the implied subsidy should be calculated in accordance with Actuarial Standard of
Practice (ASOP) No. 64. A new ASOP No. 6, issued in March 2014, requires actuaries to use expected
claims to determine liabilities for valuation dates on or after March 31, 2015; the old ASOP No. 6
allowed actuaries to use premiums rather than expected claims when an agency participated in a large
medical pool like PEMHCA.
Old ASOP No. 6
With over 1,000 agencies participating in PEMHCA, the flow illustrated above from premiums to claims
is much more complex, with significant premium subsidies between agencies within PEMHCA. In
addition, individual agencies generally have an insignificant impact on premiums. So if a PEMHCA
agency pays premiums that don’t depend on their claims, why should a liability be assigned for that
agency’s retirees based on their (expected or actual) claims? The old ASOP No. 6 recognized these
issues and generally did not require actuaries to include the implied subsidy for PEMHCA agencies.
1 Public Employees’ Medical and Hospital Care Act (CalPERS health plan)
2 Claims refer to the cost of providing all healthcare services
3 Accounting and Financial Reporting by Employers for Postemployment Benefits Other Than Pensions;
recently released GASB 75, which will replace GASB 45, also requires compliance with ASOPs
4 Measuring Retiree Group Benefits Obligations and Determining Retiree Group Benefits Program Periodic Costs or
Actuarially Determined Contributions
12
The Implied Subsidy and PEMHCA
June 2015
Page 2
411 Borel Avenue, Suite 101 y San Mateo, California 94402
main: 650/377-1600 y fax: 650/345-8057 y web: www.bartel-associates.com
Copyright 2015
New ASOP No. 6
The new ASOP No. 6 (and the old one) addresses PEMHCA’s structure, known as a pooled health plan.
The new ASOP takes the position that while many different subsidies occur, implied subsidies still exist
in pooled health plans, and including them results in a more appropriate measure of agencies’ long-term
retiree liabilities. In support of this position, there’s no guarantee the current premium structure or the
pooled health plan will continue over the long term or that the agency will continue to participate.
How is the $700 retiree “expected claims” determined?
This amount is determined based on actuarial claims cost tables. Note that the “true” benefit cost
(amount to provide medical services for each active employee and retiree) is not available from
PEMHCA.
Suppose an agency pays a fixed amount of the retiree premium, for example $200. The commitment is for
$200, so why should there be an agency liability for anything more than this?
If active premiums were prohibited from being used for retiree claims, then the agency liability would be
limited to $200 (resulting in higher retiree premiums). However, active premiums paid by the agency are
effectively being used to pay this additional retiree cost, resulting in an agency payment above the $200.
If agency employees pay a portion of active medical premiums, aren’t they paying a portion of the
agency’s implied subsidy liability?
GASB permits attributing a portion of the implied subsidy to active employees only if employees pay
more for healthcare coverage than their claims5. So in this example, the employee would need to pay
more than $500 a month toward their $600 premium. Agencies very rarely have employees pay more
than the cost of their benefits.
If an agency has very few, or even no retirees, do they get a credit for overpayment of active premiums?
No – note the pool has many other cost-sharing mechanisms, including, for example, an agency paying
the same premium as others in their region whether the actives use more or fewer services. In theory,
some premiums will be used to pay retiree claims in other agencies. In reality, there is no way to know.
In fact, an agency’s premiums could be less than employee claims.
If an agency always pays $600 for the retiree premium, but the GASB 45 valuation includes a liability for
$700, how is the liability ever defeased?
Considering only the $600 retiree premium, the liability would never be defeased. However, that should
not happen. The agency should treat the retiree payment as $700 (and the corresponding active payment
as $500). This is the basis for the GASB 45 accounting, and should also be the basis for any other
accounting treatment related to active and retiree medical. Essentially this means the agency should re-
characterize a portion of the active premium ($100 in our example) as a retiree cost.
If an agency prefunds the implied subsidy in an irrevocable trust, won’t the balance always grow and
money will never come out of the trust since the agency always pays premiums for actives and retirees?
Similar to the preceding response, the agency’s $700 retiree payment should be paid by the trust. If an
agency is prefunding, trust contributions are accumulated specifically for this purpose – to pay both the
$600 retiree premium and the $100 implied subsidy.
PEMHCA agencies pay their portion of active premiums each month when they pay the PEMHCA
invoice. Why should there be a liability for a portion of the active premium (the implied subsidy) that has
always, and will always, be paid?
The active premium shouldn’t be considered a payment only for active health coverage; it includes the
5 Guide to Implementation of GASB Statements 43 and 45 on Other Postemployment Benefits, Question #63
13
The Implied Subsidy and PEMHCA
June 2015
Page 3
411 Borel Avenue, Suite 101 y San Mateo, California 94402
main: 650/377-1600 y fax: 650/345-8057 y web: www.bartel-associates.com
Copyright 2015
(implied) payment for retirees. Therefore, the retiree liability is not for an active premium payment, but
rather for expected retiree claims, including that portion of the active premium expected to be used to pay
retiree claims.
The nature of a retiree healthcare valuation is to align retirees’ benefit cost with the service rendered
while they work for the agency. The liability exists due to the value of payments that will be made
starting at retirement, and equals the expected value of future retiree claims.
Can the implied subsidy liability be eliminated by having retirees pay additional amounts?
This question raises issues for legal counsel. From an actuarial perspective, having retirees pay more of
the premium would reduce, or potentially eliminate, the implied subsidy liability. Of course, PEMHCA
premiums are determined by CalPERS Board and we have no expectation they will move in this
direction.
14
July 24, 2015
411 Borel Avenue, Suite 101 y San Mateo, California 94402
main: 650/377-1600 y fax: 650/345-8057 y web: www.bartel-associates.com
Copyright 2015
GASB 75 is an accounting standard and does
not dictate methods or assumptions for
determining contributions to an OPEB trust,
nor does it require funding the OPEB liability.
GASB Approves New OPEB Employer Accounting Standard (No. 75)
June 2, 2015: The Governmental Accounting Standards Board approved 2 new Statements designed to improve
accounting and financial reporting for state and local government OPEB plans – GASB 74 – and employers –
GASB 75, the focus of this article. (See the GASB website for final Statements.)
GASB 75 – Accounting and Financial Reporting for Postemployment Benefits Other Than Pensions
(effective for fiscal years starting after June 15, 2017)
This Statement sets new reporting requirements for government employer OPEB plans, whether or not funded,
and replaces GASB 45. Because it follows Statement 68
(the new pension accounting standard) very closely, the
required calculations and terms may be familiar.
Steps to prepare for GASB 75
1. Decide if your agency wants to adopt early
2. Select your measurement date timing – a lag of up to 1 year is permitted
3. Discuss the actuarially determined contribution with your actuary – you may want to change from
GASB 45’s ARC to a different method.
A summary of GASB 75 follows:
Net OPEB liability on the balance sheet
• Government employers that sponsor OPEB plans will now recognize a net OPEB liability in their
statement of net position (balance sheet) – the difference between total OPEB liability (actuarial accrued
liability calculated using the entry age actuarial cost method) and fiduciary net position (plan assets at
fair value)
• Inclusion of implied subsidy in the total OPEB liability is specifically required, even for large pooled
plans such as the CalPERS PEMHCA
• Affordable Care Act “Cadillac” tax impact also must be included
• Even small plans must now have biennial valuations
• The Alternative Measurement Method (AMM) is still permitted for very small OPEB plans, but the
calculation is now more complex.
New discount rate
• The discount rate can continue to be the expected long-term rate of return on plan investments where
assets are projected to cover all future benefit payments; this requirement should be met if the employer
funds the actuarially determined contribution, provided it pays off the unfunded liability over a
reasonable period
• Other plans, including unfunded plans, must use a municipal bond rate to discount noncovered payments;
this is a yield or index rate for 20-year, tax-exempt general obligation bonds with an average rating of
AA/Aa or higher (currently below 4%)1
• Changes in the municipal bond rate between measurement dates will introduce much more volatility into
OPEB liabilities and expense, particularly for unfunded plans.
1 See http://www.bartel-associates.com/resources/select-gasb-67-68-discount-rate-indices for samples of recent rates.
15
GASB Approves New OPEB Employer Accounting Standard (Continued)
July 24, 2015
Page 2
411 Borel Avenue, Suite 101 y San Mateo, California 94402
main: 650/377-1600 y fax: 650/345-8057 y web: www.bartel-associates.com
Copyright 2015
More variable OPEB expense
• OPEB expense will now be based on the net OPEB liability change between reporting dates, with some
sources of change recognized immediately and others spread over years
• The liability impact of any benefit change related to past service is expensed immediately
• Changes in actuarial assumptions and experience gains and losses are amortized over a closed period
equal to the average remaining service of active and inactive plan members (who have no future service)
– much shorter than currently typical; investment gains and losses must be recognized in OPEB expense
over closed 5-year periods
• OPEB expense will no longer be equal to the contributions to an OPEB trust or the OPEB benefits or
premiums paid (“pay-as-you-go”).
Cost-sharing employers (where assets are pooled and available to pay benefits to employees of any
employer in the pool) report a proportionate liability
• These employers will now report a net OPEB liability and OPEB expense equal to their proportionate
share of the cost-sharing plan; may apply to counties and other agencies sponsoring pooled plans with
multiple participating employers.
Special funding situation
• This occurs when a government entity is legally responsible for contributing directly to a plan (or making
benefit payments directly) for employees of another government entity, with the amount fixed by statute
or plan provisions (example: a state legally required to contribute directly to a plan for local school
district teachers); GASB 75 requires the nonemployer entity to recognize a proportionate share of the
plan’s net OPEB liability and expense.
More extensive disclosures and required supplementary information
• These include types of benefits and covered employees, how plan contributions are determined, and
assumptions/methods used to calculate the OPEB liability; for non-cost-sharing employers, a
reconciliation of net OPEB liability from year to year is required; a new sensitivity disclosure is the net
OPEB liability calculated with 1% increases and decreases in medical trend rate and discount rate.
Insured benefits – an unusual arrangement
• An insured plan means premiums are paid to an insurer while employees are active and the insurer
guarantees to pay all plan OPEB benefits after their retirement (very different from paying annual
premiums to an insurer); OPEB expense equals current period premiums paid.
Defined contribution plan accounting unchanged
• Under a DC plan, an employee’s OPEB benefit depends only on the balance in their individual account –
which is made up of employer contributions, actual investment earnings, and possibly allocations of
other employees’ forfeitures or administrative costs
• As under current accounting standards, a DC plan’s OPEB expense equals employer contributions or
credits in the current period reduced by any forfeited amounts not reallocated to other participants; a
liability is recognized for any difference between the OPEB expense and actual employer contributions
or benefit payments.
* * *
Bartel Associates looks forward to clarifying your responsibilities under these new OPEB accounting standards.
Contact us: info@bartel-associates.com.
16
ADMINISTRATIVE SERVICES
Memorandum
To:City Council Finance Committee
From:Agnes Pabis
Date:October 27, 2022
Subject:Single Audit Update for the fiscal year ended June 30, 2022
Single Audit Requirements
The Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal
Awards (Uniform Guidance) 2 CFR 200.501 requires non-Federal entities that expend $750,000 or
more in Federal awards in a fiscal year to have a single or program-specific audit conducted for that
fiscal year with the following guidelines:
1.If the entity expends less than $750,000 in federal awards, it is required to submit written
notification of its exempt status to the SCO.
2.If the entity expends equal to or in excess of $750,000 in federal awards and that amount does
not include any state pass-through funds, the entity must submit either the audit report or an
explanation letter to the SCO. If the entity is currently being monitored by the SCO, a “No
Review Letter” will be issued to the entity in return.
3.If the entity expends equal to or in excess of $750,000 in federal awards and that amount
includes any state pass-through funds, then the SCO requires a complete single audit reporting
package to be submitted for review. Reporting packages are reviewed on a first-in, first-out
basis.
Attachment 1 transmits the City’s unaudited Schedule of Federal Awards (SEFA) for the fiscal year
ended June 30, 2022, and we expended $241,876 during the fiscal year. Following Single Audit
reporting requirements, number 1 above, Attachment 2 is the City’s notification to the State
Controller’s Officer of exemption from the Single Audit.
The City’s auditor is reviewing the City’s financial records to confirm that the SEFA accurately reflects
federal award expenditures. We expect their final opinion in December. We do not, however,anticipate
any material changes to the unaudited schedule based on our communications with the auditor.
Compliance with Auditor Rotation Requirements (AB 1345)
As part of the Single Audit process, the State Controller’s Office reminds local agencies of Assembly
Bill 1345 which added section 12410.6.(b) to Government Code regarding auditor rotation
17
requirements of public accounting firms providing audit services to local agencies. Per the Controller’s
Office:
Government Code section 12410.6.(b) indicates that commencing with the 2013-14 fiscal year,
a local agency shall not employ a public accounting firm to provide audit services to a local
agency if the lead audit partner or coordinating audit partner having primary responsibility
for the audit, or the audit partner responsible for reviewing the audit, has performed audit
services for that local agency for six consecutive fiscal years. For purposes of calculating the
six consecutive fiscal years, the local agency shall not take into account any time that a public
accounting firm was employed by that local agency prior to the 2013-14 fiscal year.
The City’s Auditor, Chavan Associates, first audited Saratoga’s finances for the fiscal year ended June
30, 2013. Chavan’s current contract ends with the completion of the June 30, 2022, independent audit.
City staff will issue a request for proposals for audit services in early 2023.
Attachments
1. Schedule of Federal Awards 2021-22
2. Single Audit Exemption Notice
18
City of Saratoga
Single Audit Grant Reconciliation (Unaudited)
6/30/2022 Single Audit
A B C D =A‐D
No. Grant Name
Pass‐
Through
Agency Project Title Grant Award
2021‐22 Total
Expenditure
Expenditures
Prior to 2021‐
22
Total
Expenditures
Remaining
Grant
Balance
Federal Grants
1 Department of
Transportation CalTrans Prospect Road Improvements 5,280,000 6,216 4,218,000 4,224,216 1,055,784
2 Department of
Transportation CalTrans Big Basin Way Sidewalk Repairs 162,000 13,752 131,311 145,063 16,937
3 Department of
Transportation CalTrans Saratoga Village Sidewalk Rehabilitation 338,000 ‐ 834 834 337,166
4 Department of
Transportation CalTrans Local Roadway Safety Plan 41,000 34,548 ‐ 34,548 6,452
5 Department of
Transportation CalTrans 4th Street Bridge 487,000 9,052 2,336 11,388 475,612
6 Department of
Transportation CalTrans Quito Bridge Phase II ‐ ROW 354,120 92,658 252,052 344,710 9,410
7 American Rescue
Plan Act of 2021 Park Sewer Lateral Replacement and Upgrades 300,000 47,948 ‐ 47,948 252,052
8 American Rescue
Plan Act of 2021 Stormwater Master Plan 482,000 24,387 ‐ 24,387 457,613
9 American Rescue
Plan Act of 2021 Prospect Road Green Infrastructure 370,000 ‐ ‐ ‐ 370,000
10 American Rescue
Plan Act of 2021 Stormwater Pollution Prevention Program 150,000 ‐ ‐ ‐ 150,000
11 American Rescue
Plan Act of 2021 Saratoga Village Rehabilitation Gap Closure 5,911,239 13,315 ‐ 13,315 5,897,924
Total Federal Grants 13,875,359 241,876 4,604,532 4,846,409 9,028,950
19
20