Employee Benefit Plan Audit Red Flags: The Top Mistakes That Cost Clients Money with Meghan Boone

As an Audit Senior, I spend much of my time helping organizations understand retirement plan compliance. It may sound technical, but at its core it affects something deeply human: the future paychecks of people who count on their savings. When I talk about compliance, I’m not just referring to abstract rules. I’m looking at the practical risks that can derail a plan—late remittances, misapplied compensation, missed enrollments, and broken match formulas. These errors don’t just create paperwork; they create real costs for participants and employers. My goal is not to make anyone fear audits, but to show how audits can serve as a lens for stronger controls and better outcomes.

Let’s start with the basics. Retirement plans vary by who offers them, who bears investment risk, and how benefits are calculated. A 401(k) allows private-sector employees to defer pay, often with an employer match, with growth tax deferred. A 403(b) mirrors that framework but is designed for schools, hospitals, and nonprofits. Defined benefit pensions promise a formula-driven payout and place market risk on the employer. These structural differences shape compliance obligations. Under ERISA, most plans face audit requirements once they reach 100 eligible participants at the start of the year; surpassing 120 locks them into large-plan status. Monitoring headcount is not a clerical task—it dictates audit scope, documentation demands, and the need for tighter process controls.

Where do plans most often stumble? Late remittances are at the top of the list. Every day withheld dollars sit outside the trust is a day of lost earnings for participants, and the Department of Labor takes that seriously. Large plans should target deposits within three business days, small plans within seven, but the real standard is “as soon as administratively possible.” Compensation definition errors are another common issue. Plan documents may define eligible pay differently for contributions and testing, and payroll configurations don’t always keep up. Add misenrollments when eligibility milestones aren’t tracked, plus match formulas that fail to update after amendments, and you have a recipe for compliance problems. These are preventable operational misses, but when they occur they can trigger corrective contributions, lost earnings calculations, and regulatory filings.

Avoiding trouble comes down to design and vigilance. Automating contribution transfers from payroll to the trust and reconciling every cycle ensures funding clears. Keeping plan documents current and aligning payroll tables with amendments the moment they take effect prevents mismatches. HRIS or payroll systems can track eligibility by hours and service dates, and exception reports can catch employees on the cusp of eligibility. Training HR and payroll teams on plan provisions is essential, especially during staff turnover or when managing part-time workforces. Documenting approvals, communications, and changes builds a clear decision trail. These steps don’t just reduce findings; they also speed auditor testing and lower the total cost of compliance.

When mistakes happen, speed matters. First, define the scope: which employees, which pay periods, and which transaction types are affected. Then correct contributions, allocations, or distributions and calculate lost earnings where needed. Document the approach and, if applicable, use the IRS Employee Plans Compliance Resolution System or the DOL’s programs to formalize remediation. Transparency earns trust; auditors look for evidence that management detected, corrected, and prevented recurrence.

Finally, make audit readiness a year-round posture. Quarterly reviews that reconcile payroll, trust, and recordkeeper data reveal drift early. Regular cross-team check-ins keep HR, payroll, and finance aligned. Law changes and plan amendments ripple into systems, so treat updates as small projects rather than afterthoughts. The outcome is straightforward: fewer surprises, cleaner audits, and retirement plans participants can rely on.