COVID-19 and the declining interest rate scenario increase the need to reinforce care in the preparation of financial statements in 2020. Among the various risks to which companies are exposed, redoubled attention should be paid to liabilities with benefit plan offered to employees for the purpose of complying with IAS-19 or Technical Pronouncement CPC 33 (R1).
One of the immediate consequences that the COVID-19 scenario brought was a drastic change in the behavior of the user of health care plans. With fear of contamination, users stopped going to doctors, clinics, hospitals and laboratories. If, on the one hand, this behavior reduces companies' expenses with the health care plan, reflecting on the company's liabilities, it is also true that as soon as the vaccine is discovered, we will have a tree in demand, due to the pent-up demand that the pandemic has brought. By this we mean that, in 2020, it is very likely that the actuarial reports evaluating liabilities with the health care plan will show actuarial gains, when compared to 2019. The question is whether or not these gains will exceed an eventual actuarial loss, due to interest rate reduction. In relation to retirement plans, the interest rate reduction is a complicating factor, because in defined benefit plans, companies have to guarantee the actuarial profitability of the plan. As interest rates on public bonds linked to the IPCA have fallen, there will be a need to seek better profitability in variable income, which represents more risk.
Within the list of benefits that can be accounted for, we highlight: retirement plans, health care plans, group life insurance, awards for length of service, eventually the FGTS fine for unfair dismissal and other benefits that contained in collective or union agreements. Those who do not have financial assets represent a higher risk of generating hidden liabilities. This is the case of medical assistance plans, given their relevance in relation to others.
Prior to 2015, only publicly traded companies were required to follow the standard. However, from the adoption of IFRS by the Federal Revenue Service in 2015, the obligation was extended to companies covered by Law No. 11.638/2007. But, after all, what does the rule say? Technical Pronouncement CPC 33 R1 establishes that the The purpose of the standard is to establish the accounting and disclosure of benefits granted to employees. To that end, the Standard requires an entity to recognize: (a) a liability when the employee has rendered service in exchange for benefits to be paid in the future; and (b) an expense when the entity uses the economic benefit arising from service received from the employee in exchange for benefits to that employee.”.
In more critical scenarios such as the current one, the need to carry out an updated assessment of assets and liabilities with such benefits is redoubled (see
IAS 34/CPC/21.IE.B9; Insights 4.4.360, 5.9.150).
However, contrary to what the standard establishes, many companies have systematically disregarded and/or resisted recording the commitments to the benefits mentioned in the preamble of this document. Judging by the content of the allegations that we have observed, this fact is due much more to the complexity of the issue and the lack of understanding on the part of those involved with the matter in the companies, than to bad faith itself. Below we list some allegations used by the managers of the companies to not record the amounts in the financial statements:
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The actuarial liability in relation to the health care plan is immaterial;
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Changing the medical care plan financing model;
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The company adopted the age group table for the health care plan;
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The company does not have a retired employee and/or the employee will not stay with the company until he or she retires;
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The health care plan is not a defined benefit plan.
None of the above claims justifies not accounting for the liability in the financial statements. In view of the above, we recommend a lot of attention and caution in the preparation of the financial statements in 2020, as the risks of not accounting for the aforementioned benefits, in accordance with Technical Pronouncement CPC 33 R1, can bring some risks to companies, especially the omission of the obligation in the financial statements not to fully reflect the company's commitment.
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