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Receivable only and participant count for audit


AmyETPA

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plan reporting is done on an accrual basis.  We are at 121 participants at beginning of plan year in part due to several participants who received a profit sharing contribution who had previously terminated and been paid out but now had this showing as in their account at the end of the plan year.  Any chance we could exclude them from the count.  I believe the answer is no but thought I'd get other opinions.

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  • 4 months later...

If plan reporting is done on a cash basis, is the answer still the same? I am thinking the answer is still the same. Regardless of whether reporting on a cash or accrual basis, the participant has an account balance. Thoughts?

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I agree with RatherBeGolfing - Also noting that you generally cannot choose cash basis one year and accrual the next, so if it is accrual based and the terminated employees are partially or fully vested then your count is 121.

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Assume a different plan that has always filed the 5500 on a cash basis. On the account statements, 120 participants have an account balance consisting of actual funds as of 12/31/2022. The plan sponsor deposited an employer contribution on April 1, 2023 for the 2022 plan year. There were two participants who had been paid out prior to 12/31/2022, who received a contribution. There is no actual money in their account. Their account consists of a receivable. As of 1/1/2023, 122 participants have an account balance if you include the receivable. My thought is even though you file on a cash basis, the participants should still be counted and the plan would be audited. Is that correct?

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