Public companies should already be aware of the new disclosures currently required for their participation in multiemployer plans. However, non-public companies need to be prepared for these same disclosure requirements to take effect for years ending after December 15, 2012. The process of obtaining the necessary information for such disclosures is likely to be challenging. Therefore, contact with plan providers and union representatives should start now.  

 

Background on the new disclosures: During September 2011 the Financial Accounting Standards Board (FASB) issued Accounting Standards Update (ASU) No. 2011-09, Compensation-Retirement Benefits-Multiemployer Plans "Disclosure about an Employer's Participation in a Multiemployer Plan."  The update came in response to a call for increased transparency regarding an employer's participation in multiemployer plans. Prior to the update, little was required to be disclosed, generally only the historical contributions to the plan in which it participates. The FASB sought to make disclosures more robust and provide users with more information about the commitments an employer has made as well as the overall status of such plans. These disclosures are intended to heighten awareness about multiemployer plan commitments as well as provide information about the potential future cash flow implications relating to these plans.

 

Disclosures now required include:

• Plan(s) name, employer ID and plan number.
• Employer contributions to each significant plan as well as total contributions for all plans.
• Level of participation in significant plans as well as an indication of whether the employer's contributions represent greater than five percent of total plan contributions.
• An indication if any plans are subject to a funding improvement plan.
• Certain details on collective bargaining agreements and whether such agreements require minimum contributions. Also, other additional qualitative details to assist readers in understanding the significance of such agreements.  
• The most recent certified funded status of the plan as defined by the Pension Protection Act of 2006 - specifically, the "zone status" of the plan. If such status is not available, an indication of whether the plan is less than 65 percent funded; between 65 and 80 percent funded; or greater than 80 percent funded.
• A description of the nature and impact of any changes affecting comparability for each period in which a statement of income is presented.

The above disclosures assume the plans financial statements being accessible from publicly available Form 5500. If this is not the case, additional disclosures would be required. The update applies to nongovernmental entities participating in multiemployer plans and issuing financial statements prepared in accordance with GAAP.

 

 

The U. S. Department of Health and Human Services, Office of Civil Rights announced they will begin fieldwork in early 2012 on HIPAA compliance audits focusing on an entity's:

• Current risk assessment,
• Administrative, physical, and technical safeguard policies and procedures for mitigating risk to protected health information (PHI), and
• Workforce members and management training program for safeguarding PHI.

 

Cloud computing has become one of the most publicized and fastes t growing Information Technology (IT) services. Cloud computing has grown from a theoretical discussion in the 1960s to a $68 billion industry in 2010. Services are expected to reach over $112 billion by 2015. How can you decide whether you should join the companies already using the cloud?

 

Potential users must plan on how they will ascend the staircase to the cloud based on their individual circumstances. There are three general steps to evaluate whether cloud computing makes sense for your organization. 

 

1. Identify the services you want the cloud to supply.

• Infrastructure as a Service (IaaS) - offers the hardware and network capability
• Platform as a Service (PaaS) - adds the operating environment to the hardware
• Software as a Service (SaaS) - provides software and management of applications

2. Identify your organization's specific requirements.

• Security - what information do you have and what is the level of sensitivity or confidentiality
• Performance - what type of processing time and response time do you need
• Control - do you want to retain control in-house or have your cloud service providers exercise control based on parameters you set
• Availability - can you withstand downtime, or are you just using the cloud to back up information
• Cost optimization or reduction
• Scalability - anticipate possible future needs

3. Identify the type of cloud to fit your needs

• Public - data center made available in a metered manner for public purchase where the infrastructure is shared with others
• Private - resources are dedicated to the specific user, which provides a higher level of control and security
• Hybrid - combination of public and private