Pulse Checks and Audits

Employers are responsible for ensuring compliance with the Plan. There are a lot of details and sometimes staff changeover, so it is very important to regularly review these responsibilities.

The annual Pulse Check is a tool to identify potential issues as they arise. It provides an opportunity for employers to ask questions and have conversations specific to their circumstances. The Pulse Check also helps identify organizational risks that could affect pension plan administration.

PSPP is here to support employers by helping to resolve any issues as they emerge rather than respond reactively to an audit finding.

The Pulse Check is not meant to replace the compliance review process, but to adjust the process. The audit – or compliance review – is completed based on risk, not a predetermined triennial schedule as in past requirements.

Section 7.7 of the Participation Agreement:
The Employer must annually complete a Pulse Check review to certify and attest that key obligations in respect of the Plan have been met (such as employee enrolment, contributions, data reporting, year-end process, and other information). In addition, the Employer must certify, to the best of their knowledge, that the appropriate Employer benefit administrator(s) attended or participated in the training sessions offered by the Corporation.

Pulse Checks

The Pulse Check helps identify organizational activities that could result in risk to the Plan and may indicate a compliance review is needed, such as:

• Organizational restructuring;
• Major changes in systems/processes that may affect pension administration;
• Turnover in pension administration staff;
• Changes to collective agreements;
• Changes to PSPP service credit policies; or
• Events that are pending, or that have occurred, that could have a material affect on plan reporting (i.e. data breaches).

Audits

Compliance reviews – also known as audits – are still necessary from time to time. Audits are not only required where significant risks were identified in the last completed review or Pulse Check, but also when a long period, such as five or more years, has passed since the last audit. Even if past audits or Pulse Checks found few or no risks, the data in the employer portal still needs to be tested to reduce technical risks in the system and protect the accuracy of member data.

Risks may include, but are not limited to:

• Multiple service calculation errors;
• Multiple contribution calculation errors;
• Unreconciled membership counts;
• Differences in reporting and source information;
• Not promptly ceasing contributions
  • When a member reaches 35 years of pensionable service
  • By December 30 the year a member turns age 71;
• Not completing the annual Pulse Check process; or
• Pension policy not compliant.

Comparison

For more information on the Audit and Compliance process, visit the Employer Hub’s Audit & Compliance webpage.