extensive. You’ll need to provide a narrative
description of the types of employees covered
and the nature of the benefits, such as medical
benefits provided to active and retired employees
and the amount of contributions to the plan for
each annual period.
If applicable, you’ll include a description of
the nature and effect of any changes that affect
comparability of total employer contributions
from period to period, such as business
combinations or divestitures, changes in the
contractual employer contribution rate, or
changes in the number of employees covered by
When Do These New Disclosure Rules
The expanded disclosures are effective for annual
reporting periods ending after December 15,
2011, for public entities and for annual reporting
periods ending after December 15, 2012, for
nonpublic entities. The amendments should
be applied retrospectively for all prior periods
presented. Early adoption is permitted.
It Pays to Be Prepared
For all contractors, especially union contractors
participating in many different plans, planning
and preparation will be key to the successful
implementation of this new standard. Although
the effective date for the disclosure requirements
is more than a year away for nonpublic entities,
the increase in the amount of information to
be disclosed means it’s a good idea to begin
gathering that information sooner rather than
Jay Olson manages construction audit engagements and
provides his clients with consulting services in the areas of
business processes, lease analysis, business combinations,
and due diligence.
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