MEMORANDUM
TO: Political Subdivisions
FROM: Micah G. Vincent, Commissioner
RE: Other Post Employment Benefits Reporting
DATE: July 30, 2013
On May 8, 2013, Governor Mike Pence signed into law House Enrolled Act 1001 (“HEA 1001”). The purpose of this memorandum is to outline other post-employment benefits (“OPEB”) reporting requirements to the Department of Local Government Finance (“Department”) under House Enrolled Act 1001 (“HEA 1001”). This memorandum is intended to be an informative bulletin; it is not a substitute for reading the law.
Section 345 introduces IC 36-1-8-17.5 (effective July 1, 2013), which requires political subdivisions to report before February 1 of each year on all other post-employment benefits, as defined by the Governmental Accounting Standards Board (“GASB”). This statute does not require a full analysis of liabilities under GASB Statement 45. The Department will release a reporting application in Gateway by the end of 2013.
The GASB definition of OPEB includes healthcare and other nonpension benefits provided to employees. Benefits typically include: medical, prescription drug, dental, vision, hearing, life insurance, long-term care benefits, and long-term disability benefits (not covered under a pension plan) that are provided after employment ends.
Each political subdivision must report, for the preceding year, its:
(1) OPEB liability;
(2) unfunded OPEB liability;
(3) OPEB assets;
(4) OPEB contributions; and
(5) OPEB expenses and expenditures.
(1) OPEB liability;
(2) unfunded OPEB liability;
(3) OPEB assets;
(4) OPEB contributions; and
(5) OPEB expenses and expenditures.
Reporting by units that complete an OPEB actuarial analysis
For units that currently complete an actuarial analysis of OPEB liabilities under GASB Statement 45, the Department requests that they submit this analysis via Gateway’s OPEB application. The Department understands that actuarial reports may not be available until after the January 31 deadline. Gateway’s OPEB application will stay open, as there is no penalty under IC 36-1-8-17.5 for having an incomplete report as of the January 31 deadline.
Reporting by units that do not complete an OPEB actuarial analysis
For units that do not currently complete an actuarial analysis, the Department will collect certain data that outline the potential OPEB liabilities. The statute does not require each political subdivision to conduct a full actuarial calculation of liabilities under GASB Statement 45; rather, political subdivisions shall include those types of benefits that would qualify as OPEB in estimating liabilities.
Any release by the Department of a filing pursuant to a Public Information Request will contain disclaimers to prevent confusion about whether the financial data comply with the Securities & Exchange Commission’s continuing disclosure requirements. The Department reminds all filers and users that these reports do not represent a full OPEB actuarial analysis and are not intended to fulfill continuing disclosure requirements.
Further information and details regarding OPEB reporting in Gateway will be available when the application is released. Questions may be directed to Eric Bussis, Director of Data Analysis, at erbussis@dlgf.in.gov or (317) 23
