RETIREMENT 

SECURITY

Challenges and 

Prospects for 

Employees of Small 

Businesses

Statement of Charles A. Jeszeck, Director 

Education, Workforce, and Income Security

United States Government Accountability Office

Testimony

Before the Committee on Health, 

Education, Labor, 

and Pensions, U.S. Senate

For Release on Delivery 

Expected at 2:30 p.m. EDT

July 16, 2013

GAO-13-748T
United States Government Accountability Office

Highlights of GAO-13-748T, a testimony 

before the Committee on Health, Education, 

Labor, and Pensions, U.S. Senate

July 16, 2013

RETIREMENT SECURITY

Challenges and Prospects for Employees of Small 

Businesses

Why GAO Did This Study

About 42 million workers, or about onethird of all private-sector employees, 

work for employers with fewer than 100 

employees, and recent federal data 

suggest many of these workers lack 

access to work-based retirement 

benefits. Despite efforts by the federal 

government to develop new plan 

designs and to increase tax incentives, 

plan sponsorship remains low among 

small employers. MEPs, a type of 

arrangement involving more than one 

employer, have been suggested as a 

potential way to increase coverage. 

This testimony describes (1) the 

challenges small employers face in 

helping ensure that their workers 

secure retirement income, and (2) 

types of MEPs and their potential to 

address these challenges. GAO drew 

from its previous reports related to 

small employer challenges in 

establishing and maintaining a 

retirement plan and recent work on 

MEPs issued from March 2012 through 

September 2012.

What GAO Recommends

GAO is not making any new 

recommendations. GAO made several 

recommendations in prior reports to 

Labor and the Internal Revenue 

Service (IRS) to address challenges 

facing small employers and to improve 

oversight and coordination for MEPs. 

The agencies generally agreed with 

GAO’s recommendations. However, 

Labor disagreed with a 

recommendation to create a single 

webportal for federal guidance. GAO 

believes consolidating information 

could benefit small employers, mainly 

because resources are scattered.

What GAO Found

About 14 percent of small employers sponsor some type of plan for their 

employees to save for retirement and these employers in general can face 

numerous challenges establishing and maintaining a plan. GAO’s March 2012 

report found that many of the small employers who were contacted said they felt 

overwhelmed by the number of plan options, plan administration requirements, 

and fiduciary responsibilities. For example, some small employers found it 

challenging to select investment funds for their plans. Small employers also cited 

other challenges in sponsoring a plan, including a lack of financial resources, 

time, and personnel. GAO’s April 2012 review of select 401(k) plans—the most 

common type of plan sponsored by small employers—found that some smaller 

plan sponsors did not know about or fully understand fees they and their 

participants were charged, such as fees associated with group annuity contracts. 

In addition to these fees, participants in small plans often pay higher 

recordkeeping and investment management fees than participants in larger 

plans. GAO’s work demonstrates the need for plan sponsors, particularly small 

sponsors, to understand fees in order to help participants secure adequate 

retirement savings. Any fees paid by participants, even a seemingly small 

amount, can significantly reduce retirement savings over time.

Small Employer Plan Sponsorship by Number of Employees in 2009

Little is known about the types of employers that participate in multiple employer 

plans (MEP), particularly because, since 2004, no publically available information 

has been collected on such employers. MEP representatives have suggested 

MEPs as a viable way for small employers to reduce the administrative and 

fiduciary responsibilities that come with sponsoring a pension plan, and for 

reducing costs, in part through asset pooling. However, GAO found that these 

advantages are not always unique to MEPs. There was also no consensus on 

the potential for MEPs to increase plan coverage. During GAO’s September 2012

study the Department of Labor (Labor) ruled that some MEPs made up of 

otherwise unrelated employers did not constitute a single pension plan but an 

arrangement under which each employer sponsored a separate plan for its own 

employees. Because this raises significant policy and compliance questions and 

data are limited, it is important that Labor gather information on participating 

employers to inform policy and oversight activities on retirement security for 

employees of small businesses. 

View GAO-13-748T. For more information, 

contact Charles A. Jeszeck at (202) 512-7215 

or jeszeckc@gao.gov. 
 

Page 1 GAO-13-748T 

Chairman Harkin, Ranking Member Alexander, and Members of the 

Committee:

I am pleased to be here today to discuss retirement security for 

employees of small businesses. One-third of all private-sector employees, 

about 42 million, work for small businesses with fewer than 100 

employees and many of these employees lack access to a work-based 

plan to save for retirement. In fact, an estimated 51 to 71 percent of 

employees of small businesses lack access to such plans.1 Over the 

years, the federal government has taken steps to encourage small 

employers to sponsor some type of plan, and legislation has been 

enacted that has established incentives such as plan types with fewer 

federal reporting requirements, higher plan contribution limits, and a tax 

credit for plan startup costs. Despite such efforts, plan sponsorship 

remains low among small employers. One proposed option to address 

this challenge is the use of pooled arrangements, such as a multiple 

employer plan (MEP), a type of arrangement comprised of more than one 

employer. GAO recently examined the characteristics of MEPs and the 

ongoing challenges that small employers face in establishing and 

maintaining a plan for their employees. My statement today describes: (1) 

the challenges small employers face in helping ensure that their workers 

secure retirement income; and (2) the types of MEPs and their potential 

to address small employers’ challenges. This statement is drawn from 

prior reports we issued from March 2012 through September 2012 

regarding small employer plans and MEPs.2 Those reports contain 

detailed explanations of the methods used to conduct our work. We 

conducted all of our work in accordance with generally accepted 

government auditing standards.

 

1 The lower percentages in these ranges are Bureau of Labor Statistics’ estimates based 

on 2011 data from the National Compensation Survey. The higher percentages are the 

Employee Benefit Research Institute’s estimates based on 2011 data from the Census 

Bureau’s Current Population Survey. 

2 GAO, Private Sector Pensions: Federal Agencies Should Collect Data and Coordinate 

Oversight of Multiple Employer Plans, GAO-12-665 (Washington, D.C.: Sept. 13, 2012); 

401(k) Plans: Increased Educational Outreach and Broader Oversight May Help Reduce 

Plan Fees, GAO-12-325 (Washington, D.C.: April 24, 2012); and Private Pensions: Better 

Agency Coordination Could Help Small Employers Address Challenges to Plan 

Sponsorship, GAO-12-326 (Washington, D.C.: Mar. 5, 2012). 

 
 

Page 2 GAO-13-748T 

To encourage employers to provide retirement benefits for their 

employees, the federal government provides preferential tax treatment 

under the Internal Revenue Code (IRC) for pension plans that meet 

certain requirements. In addition, the Employee Retirement Income 

Security Act of 1974 (ERISA)3 sets forth certain protections for 

participants in private-sector pension plans4 and establishes standards of 

conduct for those who manage such plans and their assets, generally 

called fiduciaries.5 To the extent they qualify as fiduciaries under the law, 

plan sponsors assume certain responsibilities and potential liability under 

ERISA. For example, a fiduciary must act prudently and in the sole 

interest of the plan’s participants and their beneficiaries.6

Employers may choose to sponsor a plan for their employees from one of 

three categories: employer-sponsored individual retirement arrangement 

(IRA) plans; defined contribution (DC) plans; and defined benefit (DB) 

plans.

Responsibilities 

of plan sponsors and other fiduciaries may include reporting plan 

information to the federal government and to participants, selecting and 

monitoring investment options the plan will offer, and ensuring that the 

services provided to their plans are necessary and that the cost of those 

services is reasonable.

7

 

3 Pub. L. No. 93-406, 88 Stat. 829 (codified in part at 29 U.S.C. §§ 1002 -1461). 

Small employers may also choose to sponsor a Savings Incentive 

Match Plans for Employees (SIMPLE) IRA. Employer-sponsored IRAs 

and DC plans generally allow employers, employees, or both to make 

contributions to individual employee accounts within the plan. DC plans 

4 In this statement, consistent with ERISA, we use the term “pension” to refer generally to 

all types of private retirement plans, not just defined benefit plans.

5 Under ERISA, a fiduciary is anyone who exercises any discretionary authority or 

discretionary control respecting management of such plan or exercises any authority or 

control respecting management or disposition of its assets or renders investment advice 

for a fee or compensation, direct or indirect, with respect to any moneys or other property 

of such plan, or has authority to do so, or has any discretionary authority or discretionary 

responsibility in the administration of the plan. 29 U.S.C. § 1002(21)(A).

6 29 U.S.C. § 1104.

7 Defined benefit plans are plans in which employers generally maintain a fund to provide 

a fixed level of monthly retirement income based on a formula specified in the plan. 

Defined contribution plans are plans in which retirement income is based on employer and 

employee contributions and the performance of investments in individual employee 

accounts.

Background 
 

Page 3 GAO-13-748T 

tend to have higher contribution limits for employees than employersponsored IRA plans. However, DC plans are also subject to more 

reporting and other requirements.8

A MEP is a type of arrangement involving more than one employer, and 

can be structured as either a DB or a DC plan. A MEP is distinct from a 

single employer plan that is established and maintained by one employer 

for its employees.9 MEPs are also distinct from multiemployer plans that 

are also maintained by more than one employer, in that MEPs need not 

be established by one or more employee organizations pursuant to a 

collective bargaining agreement.10

Some MEPs were formed long before the enactment of ERISA in 1974. 

Our September 2012 report identified four types of MEPs: association, 

corporate, professional employer organization (PEO), and open MEPs.

When employers decide to participate 

in a MEP, they legally adopt the plan as their own as participating 

employers. A participating employer may sign an agreement that serves 

to identify the plan terms that will apply to its employees.

11

 

8 For additional information about the rules and reporting requirements plans are subject 

to, see GAO-12-326. 

MEPs maintained by most associations we interviewed included over 100 

participating employers and were often organized around a common 

trade or industry that served smaller employers. However, the majority of 

the largest 25 MEPs are corporate. These sponsors tend to be large 

Fortune 500 or Global 500 corporations with few participating 

9 29 U.S.C. § 1002(41) and (42).

10 For more information on multiemployer plans, see GAO, Private Pensions: Timely 

Action Needed to Address Impending Multiemployer Plan Insolvencies, GAO-13-240

(Washington, D.C.: Mar 28, 2013). Another plan-type that can involve multiple employers 

are master or prototype plans, which are largely based on a uniform plan document 

sponsored by an organization for adoption by employers who are either its customers or 

members.

11 GAO-12-665. 
 

Page 4 GAO-13-748T 

employers.12

Other types of MEPs appear to have become popular more recently and 

are often structured as DC plans. These include MEPs sponsored by 

PEOs, which are firms that provide payroll and other human resources 

services to clients, and so called “open” MEPs sponsored by firms that do 

not purport to employ plan participants. Employers in these “open” MEPs 

are related solely by their participation in the plan.

Of the association and corporate MEPs we interviewed, all 

sponsored a traditional DB plan, while the other types generally 

sponsored DC plans only.

13

To operate an employer sponsored plan, employers may hire companies 

to provide services, such as legal, accounting, trustee/custodial, record 

keeping, investment management, investment education, or advice. 

These companies, typically referred to as plan service providers, can 

assist with administrative functions associated with establishing and 

maintaining a plan, including, for example, any required testing, plan 

 

12 Those we interviewed maintained MEPs to cover subsidiaries not under common 

control. For most purposes, all employees of employers in the same controlled group are 

treated as employed by a single employer. 26 U.S.C. § 414(b). The status of these large, 

corporate plans as MEPs may be temporary if the transactions that resulted in them 

becoming MEPs are undone. For example, one plan sponsor representative we 

interviewed said that the sponsor’s DB and DC plans became MEPs in the early-to-mid 

2000s as a result of a merger within a business segment. Not long after, however, that 

particular segment was spun-off from the company and, by sometime in 2012, both the 

DB and DC plans will no longer be MEPs, but may be single-employer plans. The extent 

to which two or more corporations are considered in the same controlled group has to do 

chiefly with the percentage of ownership one has in the other. 26 U.S.C. § 1563. 

13 On May 25, 2012, the Department of Labor (Labor) issued an advisory opinion on an 

open MEP arrangement and found that it was not a single employee benefit plan under 

Title I of ERISA. The Internal Revenue Service (IRS) has found at least one open MEP 

qualified for preferential tax treatment. IRS does not take into consideration a MEP’s 

status under Title I of ERISA when considering whether it qualifies for preferential tax 

treatment. IRS focuses solely on compliance with IRC provisions. Labor’s advisory opinion

means, in effect, that an open MEP may be simultaneously considered both a single plan 

by IRS, for purposes of certain tax laws, and a series of plans by Labor. Dept. of Labor 

Advisory Op. 2012-04A.
 

Page 5 GAO-13-748T 

audits, or filing of government reports, chiefly the Form 5500.14 Service 

providers are compensated for their services generally in the form of fees 

charged to the plan, which may be passed on to plan participants.15 Plan 

fees, even seemingly small ones, can significantly reduce a participant’s 

retirement savings over the course of a career. Service providers charge 

an array of fees depending on the type of product and arrangement the 

provider may have with other entities that provide plan services. Some 

investment fees may be paid by third parties in connection with 

investment-related services, also known as revenue sharing,16

To respond to concerns about the lack of access to employer-sponsored 

plans for employees of small businesses, legislation has been enacted to 

lower costs, simplify requirements, and ease administrative burdens. For 

example, the Revenue Act of 1978

which are 

ultimately indirectly paid for by the plan or its participants.

17 and the Small Business Job 

Protection Act of 199618 established the SEP (Simplified Employee 

Pension) IRA plan and the SIMPLE IRA plan, respectively, featuring 

fewer compliance requirements than other plan types. The Economic 

Growth and Tax Relief Reconciliation Act of 2001 (EGTRRA)19

 

14 Most tax-qualified plans are required to annually file a Form 5500, developed jointly by 

Labor, the IRS, and the Pension Benefit Guaranty Corporation (PBGC) to satisfy certain 

annual reporting requirements under ERISA and the Internal Revenue Code. ERISA 

established a reporting and disclosure framework, in part, to protect the interests of 

participants and beneficiaries by requiring that certain financial and other information be 

provided to participants and beneficiaries, as well as to the federal government. Some 

small plans may be eligible to use a simplified version of Form 5500. SIMPLE IRA and 

Simplified Employee Pension (SEP) IRA plans that comply with certain alternative 

methods of compliance are not required to file Form 5500. 

also 

15 For details about how service providers charge plan fees and the types of fees that can 

be charged, see GAO-12-325. 

16 Revenue sharing, in the 401(k) plan industry, generally refers to indirect payments 

made from one service provider, such as the investment fund provider, to another service 

provider in connection with services provided to the plan, rather than payments made 

directly by the plan sponsor for plan services. For example, a plan’s record keeper and 

investment fund manager may have an arrangement where the investment fund company 

collects sub-TA fees from plan assets invested in a particular fund that may then be used 

as a credit to offset the record keeper’s fees.

17 Pub. L. No. 95-600, § 152, 92 Stat. 2763, 2791.

18 Pub. L. No. 104-188, § 1421, 110 Stat. 1755, 1792.

19 Pub. L. No. 107-16, 115 Stat. 38.
 

Page 6 GAO-13-748T 

included a number of provisions that affected small businesses. For 

example, EGTRRA eliminated top-heavy testing requirements20 for safe 

harbor 401(k) plans,21 increased contribution limits for employersponsored IRA plans and 401(k) plans, and created a tax credit for small 

employers to offset startup costs, including the cost of educating 

employees about a new plan.22 EGTRRA also created a tax credit for 

individuals within certain income limits who make eligible contributions to 

retirement plans. The Pension Protection Act of 2006,23 among other 

changes, made these EGTRRA provisions permanent and established 

additional provisions that support plan participation by rank-and-file 

employees, such as automatic enrollment. Despite these incentives and 

legislative efforts, the percentage of the U.S. workforce that participates in 

a pension plan remains around 50 percent.24

To help encourage plan sponsorship, federal agencies conduct education 

and outreach activities, and provide information about retirement plans for 

small employers. The Department of Labor (Labor), the Internal Revenue 

Service (IRS), and the Small Business Administration (SBA)—which 

maintains an extensive network of field offices—have collaborated with 

each other and with national and local organizations to develop 

information on small employer retirement plans and conduct outreach 

 

20 Some plans may be subject to top-heavy requirements and be required to conduct 

further testing to ensure a minimum level of benefits are provided to rank-and-file workers 

in plans that are sponsored by owner-dominated firms, where the majority of benefits 

accrue to “key” employees, such as owners and top executives. 

21 26 U,S,C, § 401(k)(12). Safe harbor 401(k) plans require employers to either make a 

specified matching contribution to each participating employee’s account or contribute at 

least 3 percent of compensation to all nonhighly compensated eligible employees.

22 The credit for small employer pension plan startup costs applies to certain startup costs 

in connection with the establishment of a new qualified DB plan, DC plan (including 401(k) 

plans), SIMPLE IRA plan, or SEP IRA plan. To be eligible, an employer must have no 

more than 100 employees who received at least $5,000 of compensation in the preceding 

year. The credit equals 50 percent of qualified startup costs, which include administration 

costs and employee education, up to a maximum of $500 per year (for the first 3 years of 

the plan). 26 U.S.C. § 45E.

23 Pub. L. No. 109-280, 120 Stat. 780. EGTRRA was set to expire on December 31, 2010, 

but the Pension Protection Act of 2006 made permanent EGTRRA’s provisions relating to 

pensions and IRAs.

24 John J. Topoleski, U.S. Household Savings for Retirement in 2010 (Washington, D.C.: 

Congressional Research Service, April. 30, 2013).
 

Page 7 GAO-13-748T 

with small employers. For example, Labor, IRS, SBA and the U.S. 

Chamber of Commerce partnered to create the Choosing a Retirement 

Solution Campaign, which targets small employers and their employees.

Labor’s Employee Benefits Security Administration (EBSA) is the primary 

agency responsible for protecting private-sector pension plan participants 

from the misuse or theft of their pension assets, among other things, and 

carries out its responsibilities through such activities as issuing 

regulations and conducting investigations of plan fiduciaries and service 

providers. EBSA also issues advisory opinions in which it facilitates 

compliance with ERISA through interpretative guidance.

Small Employers Face 

Challenges Helping 

Their Workers Save 

for Retirement
 

Page 8 GAO-13-748T 

As we reported in March 2012,25 retirement plan sponsorship is low 

among small employers, which may reflect the challenges employers face 

in establishing and maintaining a plan.26 Our analysis of available Labor 

and IRS data found that about 14 percent of small employers sponsored 

some type of plan in 2009.27 As shown in figure 1, the smallest 

employers—those with 1 to 4 employees—had the lowest sponsorship 

rate at 5 percent but even employers with 26 to 100 employees had a 

sponsorship rate of 31 percent.28 To put this in context, about 50 percent 

of the private sector workforce at any one time participates in an 

employer-sponsored pension plan. Also, small employers paying average 

annual wages of $50,000 to $99,999 had the highest rate of plan 

sponsorship at 34 percent while small employers paying average wages 

of under $10,000 had the lowest sponsorship rate at 3 percent.

 

25 GAO-12-326. 

26 For the purposes of this statement, we defined a small employer as a for-profit firm with 

at least 1 employee and no more than 100 employees. Because not all employees may 

participate or be eligible to participate in the plan, we define a “small plan” as those with 

fewer than 50 participants.

27 This sponsorship rate does not include small employers that sponsor SEP IRAs 

because the IRS currently does not have a means to collect data on employers that 

sponsor this plan type. The sponsorship rate also does not include small employers that 

participated only in MEPs or multiemployer retirement plans. In addition, for the purposes 

of this study, we chose to use a “firm” as our unit of analysis, which may differ from other 

studies. For example, the BLS’s 2010 National Compensation Survey used 

“establishment” as a unit of analysis. An establishment differs from a firm in that an 

establishment can be a business at a single physical location or a branch of a larger 

companying operating multiple branches, where we defined a firm as a complete, forprofit, independent business. For additional information on the scope and methodology of 

this analysis, see GAO-12-326. 

28 Given the traditional dynamism of business formation in the U.S., one would expect the 

“churn” rate of new business formations and dissolutions to result in a low sponsorship 

rate for the smallest employers.

Complex Rules, Resource 

Constraints, and Financial 

Instability Contribute to 

Low Rates of Plan 

Sponsorship by Small 

Employers
 

Page 9 GAO-13-748T 

Figure 1: Small Employer Plan Sponsorship by Number of Employees in 2009 

When we met with small employers and other stakeholders, they 

identified a variety of factors as challenges to sponsoring retirement plans 

or as reasons for terminating existing plans.29

Other areas of concern for small employers centered on a sponsor’s 

fiduciary responsibilities with respect to managing or controlling plan 

assets. Specifically, some small employer sponsors found the fiduciary 

responsibility of selecting investment fund choices for their plans 

particularly challenging. A small employer with a 401(k) plan described 

the difficulties of selecting investment options with an appropriate balance 

One commonly cited 

concern focused on the multiplicity of plan types and the burden of 

paperwork and administration. For example, some small employers and 

retirement experts said that the broad range of plan types and features 

made it difficult for small employers to compare and choose plans. 

Another small employer who previously sponsored a 401(k) plan with a 

company match said the amount of required plan paperwork, including 

generating annual reports, was a key reason he terminated it.

 

29 For our March 2012 report, we conducted structured interviews with groups of small 

employers that did and did not sponsor plans. Our interview protocols also sought to 

identify and interview small employers of varying sizes and from various industries. While 

the findings from these interviews are not generalizable to the overall population of small 

employers, these discussions were extensive and included separate interviews with both 

sponsors and nonsponsors of pension plans to discuss the overall challenges of pension 

plan sponsorship. For additional details about our small group interviews, see GAO-12-

326. 
 

Page 10 GAO-13-748T 

of risk for a workforce that includes both younger and older workers. 

Moreover, a number of stakeholders said some small employers may not 

have an adequate understanding of their fiduciary duties and are not 

always aware of all their legal responsibilities. One service provider 

explained that some small employers mistakenly believe that all fiduciary 

responsibilities and liabilities are transferred to a service provider when 

they are hired. Another expert noted that some small employers have an 

exaggerated sense of the possible liabilities that being a fiduciary carries, 

and may avoid sponsoring a plan out of fear of being sued by their 

employees.

In addition to these challenges, smaller or newer firms may be unwilling 

or unable to sponsor plans because they lack sufficient financial 

resources, time, and personnel. For instance, smaller employers noted 

that startup and ongoing costs involved with maintaining a plan, costs 

associated with reporting and testing requirements, administrative fees 

paid to an outside party, and any employer requirements to match 

employee contributions were barriers to plan sponsorship. Small 

employers also expressed the need to reach a certain level of profitability 

before they would consider sponsoring a plan and that general economic 

uncertainty makes them reluctant to commit to such long-term expenses.

Low employee demand for an employer-sponsored plan may also be a 

challenge for small employers. For example, a number of small 

employers stated that employees prioritized health care benefits over 

retirement benefits. One small employer thought that, given the limited 

funds available to contribute towards benefits, his employees would 

prefer those resources be applied toward lowering the employees’ share 

of health insurance premiums. Small employers emphasized that offering 

health care benefits was necessary to attract quality employees. 

Additionally, some small employers, such as those who described having 

a younger workforce, stated that their employees were less concerned 

about saving for retirement and, as a result, were not demanding 

retirement benefits. Other small employers told us that employees, 

particularly those with low pay, do not have any interest in retirement 

benefits because they live paycheck to paycheck and are less likely to 

have funds left over to contribute to a plan. For example, one small 

employer discontinued his plan when too few of his employees—most of 

whom he described as low-wage—participated in the plan. Another small 

employer noted that even senior-level managers in his business did not 

participate in the plan. However, a retirement expert stated that while 

some employees might not be interested in participating in a retirement 

plan, he believed the perceived lack of demand to be exaggerated. He 
 

Page 11 GAO-13-748T 

added that he believed some businesses may use lack of employee 

demand as an excuse when the small employer was not interested in 

sponsoring a plan.

In March 2012, we made a recommendation to Labor to convene an 

interagency task force with the Department of the Treasury, IRS, SBA, 

and other appropriate agencies to review, analyze, and address the 

challenges small employers face in helping ensure retirement security.30

The agencies generally agreed with this recommendation, however, 

Labor disagreed with one aspect of our recommendation, which was for 

the task force to create a single webportal for federal guidance. We 

believe consolidating plan information onto one webportal could benefit 

small employers, mainly because federal resources are scattered across 

different sites. We also made a recommendation to the Department of the 

Treasury to collect additional information on IRA plans.

Small employers are more likely to sponsor 401(k) plans and participants 

of these plans tend to pay higher fees than larger plans. According to our 

analysis of Labor and IRS data, out of slightly more than 712,000 small 

employers that sponsored a single type of plan in 2009, about 46 percent 

sponsored a 401(k) plan, 40 percent a SIMPLE IRA, and the remaining 

employers sponsored other types of plans, including DB and non-401(k) 

profit sharing plans.31

Regarding fees, plans with fewer than 100 participants account for the 

majority of 401(k) plans, and these plans usually pay higher fees. 

According to industry experts and research, plans with fewer participants 

generally have lower plan assets, and therefore pay higher fees as a 

percentage of assets than plans with more assets or older plans that have 

Experts have identified low contribution rates as a 

key problem facing workers seeking to secure an adequate retirement 

income. In 2011, the average account balance of 401(k) plans with 100 or 

fewer participants was about $59,000. This may reflect the challenges 

facing participants in small plans of not only contributing faithfully, but 

also investing prudently and avoiding high fees.

 

30 GAO-12-326. 

31 For additional information about the number and types of other plans sponsored, see 

GAO-12-326. 

Participants of Small 

Employer 401(k) Plans are 

Likely to Pay Higher Fees
 

Page 12 GAO-13-748T 

grown their assets over time. Service providers and an industry expert we 

met with noted that administrative fees to start a 401(k) plan can be 

significant for small plans. Additionally, representatives of a retirement 

industry organization said that it may be difficult for sponsors of small 

plans to negotiate for lower fees because assets in these plans are 

modest.

In April 2012, we reported that participants in smaller plans typically pay 

higher fees than participants in larger plans.32 Specifically, our nationally 

representative survey of plan sponsors found that participants in plans 

with fewer than 50 participants paid an average of 0.43 percent of their 

plan assets annually, while participants in larger plans—those with more 

than 500 participants—paid 0.22 percent for record keeping and 

administrative services.33 On top of these fees, participants likely paid 

other plan fees. For example, according to survey results, in about 69 

percent of small plans, participants paid all of the investment fees (see 

fig. 2 for additional details), which ranged from less than 0.01 percent to 

3.24 percent of assets.34

 

32 GAO-12-325. This work was conducted before Labor finalized regulations regarding 

disclosure of service providers’ direct and indirect compensation; and before regulations to 

disclose certain plan and investment-related information, such as fees, to participants and 

their beneficiaries in participant-directed individual accounts were in effect. 29 C.F.R. §§ 

2550.408b-2 and 2550.404a-5 (2012).

33 For further details on the design of our 401(k) plan sponsor survey on fees, see 

GAO-12-325. 

34 Our estimates of investment management fees are not generalizable to the population 

of 401(k) plans.
 

Page 13 GAO-13-748T 

Figure 2: Among Survey Respondents Who Provided Amounts, the Percentage of 

Investment Management Fees Paid by Participants, Sponsors, or Both, 2010

Note: Percentages may not total to 100 because of rounding. Estimates in this figure have margins of 

error that are less than plus or minus 24 percentage points.

Investment management fees account for the majority of 410(k) plan fees, 

but sponsors of about 50 percent of plans we surveyed did not know if 

they or their participants paid investment management fees or believed 

these fees were waived. This was especially prevalent among smaller 

plans. For example, respondents of 57 percent of small plans either did 

not know about fees or claimed fees were waived, compared with 31 

percent of large plans. Some of these sponsors may not know about 

investment management fees, because these fees are usually borne by 

participants and are typically charged against participants’ assets, as 

opposed to being invoiced to the plan sponsor.
 

Page 14 GAO-13-748T 

We also found instances in which participants paid for consulting and 

advisory services to help the employer with their plan responsibilities, 

such as monitoring investments and selecting plan vendors. These fees 

were also higher for participants in smaller plans. For example, while 

participants in small plans paid approximately 0.29 percent annually, the 

median amount participants in large plans (500 or more participants) paid 

was 0.07 percent of assets.

A lack of understanding on the part of plan sponsors about how fees are 

charged can also have adverse effects on participants’ retirement savings 

by unknowingly passing those fees along to participants. As noted earlier, 

understanding these fee arrangements may be even more challenging for 

small employers, who lack the time and resources to fully identify and 

Some Common Investment-Related Fees

• Management fees: These fees are typically paid out of fund assets to 

the fund’s investment adviser for investment portfolio management, 

other management fees payable to the fund’s investment adviser or 

its affiliates, and administrative fees payable to the investment adviser 

that may not be included in some of the fees identified below.

• Marketing and distribution fees, also known as 12b-1 fees: These 

fees may be used to pay commissions to brokers and other 

salespersons, to pay for advertising and other costs of promoting the 

fund to investors, and to pay various service providers of a 401(k) 

plan pursuant to a bundled services arrangement. They are usually 

between 0.25 percent and 1.00 percent of assets annually.

• Sub-transfer agent (sub-TA) fees: These fees are typically used to 

reimburse a plan’s record keeper for shareholder services that the 

fund would have otherwise provided, such as maintaining participantlevel accounts and distributing the fund’s prospectus.

• Trading or transaction costs: These fees are associated with an 

investment manager’s buying and selling of securities within a 

particular investment vehicle, such as a mutual fund, which can 

include commissions. These also include costs associated with 

portfolio turnover. 

• Wrap fees: These fees are usually associated with insurance 

products, such as group variable annuities. They are aggregate fees 

that encompass multiple components, such as investment 

management fees, mortality risk and administrative expense charges, 

and surrender and transfer charges.
 

Page 15 GAO-13-748T 

understand them. Our review of selected plans indicates that some 

smaller plan sponsors did not know about or fully understand revenue 

sharing arrangements, in which fees for plan services are indirectly 

charged to the plan through an outside entity. For example, in comparing 

survey responses to annual plan investment reports, we found that a plan 

with about $6 million in assets unknowingly paid about $5,000 in 12b-1 

fees and other revenue sharing fees—a type of revenue sharing fee used 

to pay commissions to brokers, advertising and other costs of promoting a 

fund to investors, and various other marketing and distribution services. 

Moreover, plan sponsors that were aware of revenue sharing 

arrangements may not have fully understood the impact of these 

arrangements on plan services and plan fees, and therefore likely paid 

higher fees than they reported on our survey. For example, a plan with 65 

participants and about $5.8 million in plan assets reported that the 

company did not pay anything for record keeping and administrative fees, 

though the fee report the sponsor provided indicated that these fees in 

total were about $10,700—about $5,900 was invoiced to the company 

and roughly $4,800 was paid to the provider from revenue sharing fees 

collected from participants’ asset accounts. Failing to understand these 

arrangements can have adverse effects on the plan sponsor and 

participants.35

Small plan sponsors may also not be aware of other fees that participants 

are paying, such as wrap fees associated with group annuity contracts. 

These contracts are products that place a “wrapper” of benefits, namely a 

guaranteed lifetime annuity income or a minimum death benefit, around a 

bundle of investments that are similar to mutual funds—called separate 

accounts or subaccounts. Some service providers we met with said that 

plan sponsors often do not know that they are invested in group variable 

annuities and are unaware of the associated fees. These wrap fees 

include administrative fees and a mortality and expense risk charge, 

which is typically in the range of 1.25 percent of assets per year.36

 

35 A short video illustrating a hypothetical example of how revenue sharing arrangements 

can work and how the fees for services change over time under such an arrangement is 

available at http://www.gao.gov/products/GAO-12-325. 

36 These fees can be significant, and plan sponsors are likely contracting with providers 

that charge higher fee rates without knowing the benefits for which they and their 

participants are paying. Moreover, without knowing if their plan is a group annuity contract, 

plan sponsors cannot adequately assess whether the benefits tied to that product are 

worth the associated fees.
 

Page 16 GAO-13-748T 

Finally, small plan sponsors may not be aware that their participants are 

paying potentially significant transaction costs (also known as trading 

costs). These costs are commonly paid for indirectly by plan participants 

and typically include commissions incurred when an investment manager 

buys and sells securities within a particular investment vehicle.37 While 

transaction costs are common among mutual funds, and more than 80 

percent of 401(k) plans in our survey offer mutual funds, sponsors of an 

estimated 48 percent of plans did not know if their plans incurred 

transaction costs through the deduction from participants’ returns on 

investments. We previously reported that the transaction cost for an 

investment option was as high as 2.72 percent.38

Our work demonstrates the need for plan sponsors, particularly small 

sponsors, to understand plan fees in order to help participants secure 

adequate retirement savings. Any fees paid by participants, even a 

seemingly small amount, such as a 1 percent annual fee, can significantly 

reduce retirement savings over time, as shown in figure 3. 

 

37 There are also “transaction costs” associated with plan participant actions, such as 

withdrawals and taking a loan from their 401(k) plan accounts; however, this definition of 

transaction costs differs from the types of transactions referred to in this testimony.

38 Our analysis of transaction costs was limited to 83 plans; see GAO-12-325 for 

additional details about this analysis.
 

Page 17 GAO-13-748T 

Figure 3: Effect of 1-Percentage Point in Higher Annual Fees on a $20,000 DC Plan Balance Invested over 20 Years

In our April 2012 report, we made a number of recommendations to help 

small and large plan sponsors better understand and monitor fees.39

Specifically, we recommended that Labor develop and implement 

outreach and education initiatives that actively engage sponsors and we 

recommended enhancing online access to available plan fee information. 

Labor generally agreed with these recommendations. We will continue to 

monitor Labor’s actions to address these recommendations.

 

39 GAO-12-325. 
 

Page 18 GAO-13-748T 

As we reported in September 2012, little is known about the employers 

that participate in MEPs, or even the number of MEPs by type, in part 

because the federal government no longer collects these data.40 As of 

2009, the most recent data available for our September 2012 report, 

MEPs represented only a small portion of the pension universe.41

Specifically, DB MEPs represented 0.7 percent of all DB plans, about 6.0 

percent of all DB assets and 5.0 percent of all DB participants. DC MEPs 

represented about the same percentage of all DC plans, assets and 

participants. In our September 2012 report, we found smaller employers 

in MEPs were mainly participating in association-sponsored MEPs.42 Two 

associations told us their participating employers averaged between 20 

and 60 employees. However, one MEP sponsored by a PEO43 reported

that the typical participating employer in its plan was small as well. In 

particular, little data exist on the current number of PEO or open MEP 

plan types,44 their asset size, the number of participants, or the 

participating employers. Relative to other MEP types, PEO and open 

MEPs are the newest, and may be the only types actively marketing their 

MEPs to participating employers.45

MEPs have been suggested by PEO and open MEP representatives as a 

viable way for small employers to reduce their administrative

responsibility for their pension plans. Several MEP representatives said 

 

40 GAO-12-665. 

41 While the federal government stopped collecting data on MEP participating employers 

in 2005, the most recent Form 5500 plan-level data on MEPs was from 2009. 

42 GAO-12-665. 

43 A PEO is a firm that provides payroll and other human resources services to clients.

44 The key differences between PEO MEPs and open MEPs appear to be that open MEPs 

do not (1) offer payroll management or other administrative services PEOs typically offer, 

or (2) purport to be an employer of plan participants. Employers in open MEPs are related 

solely by their participation in the MEP.

45 Key public data on participating employers have not been collected since 2004. 

Additionally, participating employer information alone does not identify sponsor types or 

specific employer relationships that could indicate whether the MEP is sponsored by, for 

example, a large corporation, PEO, or association. According to officials we interviewed, 

the information that was collected in 2004 and prior was also not particularly useful 

because it was not required on an annual schedule for all employers—and the information 

that was collected was not particularly direct or timely. For our September 2012 report, 

GAO-12-665, we were able to obtain such information by interviewing plan 

representatives.

Little Information 

Available About 

Current MEPs and 

Their Potential 

to Increase Small 

Business 

Sponsorship 
 

Page 19 GAO-13-748T 

MEP administrators can complete the record keeping and the annual 

testing, and can submit required filings such as a single Form 5500 for 

the MEP on behalf of all the participating employers. Furthermore, 

employees can more easily move among employers in the plan. For 

example, in a DB MEP sponsored by an association, as long as a 

participant remains an employee of an employer within the association, 

participants can change employers and continue earning vesting service 

credit in the same plan. A small employer sponsoring a single employer 

plan can also contract with a service provider to perform administrative 

functions, but a couple of interviewees said employers not already 

offering plans might find it easier and faster to join a MEP than to create 

their own single employer plan. MEPs have also been suggested by 

some as a possible means to lower the costs of plan sponsorship, since 

participating employers can pool assets to obtain lower pricing available 

to larger plans. One expert we spoke with said that certain association 

plans have been very effective at offering efficient, cost-effective 

retirement options for their members. Furthermore, a couple of 

interviewees said MEPs may also reduce costs for employers since they 

will not need to spend money to create an initial plan document, as they 

would in establishing a new single-employer plan.

As we found in September 2012, another possible benefit of MEPs, 

according to some MEP marketing material, is reducing participating 

employers’ fiduciary liability since the MEP administrator takes on some 

fiduciary duties.46 However, it is not clear how much relief from fiduciary 

liability a MEP can provide to participating employers, and it is not clear 

that such relief is unique to MEPs. For example, small employers may 

also be able to receive a similar degree of reduced fiduciary liability by 

using a service provider to administer the employer’s own plan. Because 

small employers may not be familiar with how to manage a plan, reduced 

fiduciary liability may be an attractive feature for them, and, in our March 

2012 small employer report,47

 

46

small employers identified possible 

fiduciary responsibility as a barrier to sponsoring a pension plan. 

However, while MEP representatives and MEP marketing materials 

sometimes stated otherwise, participating employers retain some 

fiduciary responsibility, according to Labor officials. At a minimum, 

GAO-12-665. 

47 GAO-12-326. 
 

Page 20 GAO-13-748T 

participating employers must still select a MEP to join and monitor a 

plan’s investments and fees, which Labor considers a fiduciary function.

Overall, no consensus existed among MEP representatives and pension 

experts on the potential for MEPs to substantially expand coverage. 

Large associations can provide the option of joining a MEP to their 

members. That option is unavailable to small employers not part of a 

membership organization looking out for their interests. The extent to 

which small employers can join a MEP may depend on whether a MEP is 

actively marketed and sold, since one pension expert observed that small 

employers do not extensively research pension plans or actively seek 

them out. Additionally, employers who choose to become part of a MEP 

for the first time may already have been providing a plan for their 

employees. While a couple of the MEP representatives we spoke with 

specifically targeted employers without plans, several targeted 

businesses with existing plans.

From Labor’s perspective, their primary regulatory concern centers on 

one type of MEP, the open MEP. During our review for our September 

2012 report, Labor issued an advisory opinion stating that one particular 

open MEP did not constitute a pension plan under ERISA because it was 

not established or maintained by an employer or an employee 

organization.48 Labor determined that, in the case of this MEP, 

participating employers did not constitute a bona fide employer group or 

association, sufficient to be considered an employer sponsoring the 

arrangement, because, among other things, they did not exercise 

sufficient control over the plan.49

 

48 An advisory opinion, which is limited to the facts in the opinion, can be relied upon, as a 

legal matter, only by the parties in the opinion. However, these opinions serve as 

guidance to others on what arrangements are considered employee benefit plans under 

ERISA. 

As a consequence of this guidance, the 

49 Dept. of Labor Advisory. Op 2012-04A. On both MEWAs (Multiple Employer Welfare 

Arrangements), arrangements providing welfare benefits such as health coverage and 

MEPs, Labor has held that multiple employers may maintain a single plan through a bona 

fide employer group or association of employers. However, Labor has been careful to 

define the nature of such an association in advisory opinions. Labor’s advisory opinions on 

MEWAs may have been prompted by abuses by their promoters. When state insurance 

regulators found such practices violated their insurance laws, MEWAs claimed to be 

ERISA-covered plans preempted from state regulation. According to a Labor official, the 

MEWAs that failed to maintain adequate funds to pay promised benefits were often 

comprised of otherwise unrelated employers. Labor is still confronting challenges 

stemming from abuses of participants. For additional details, see GAO-12-665. 
 

Page 21 GAO-13-748T 

participating employers in that open MEP were instead determined to 

each be the sponsors of their own, individual plans. Association MEP 

representatives told us Labor’s guidance had no affect on their plans.50

As a practical matter, Labor’s ruling is being treated by many as meaning 

that individual participating employers in an open MEP have to comply 

with any reporting, auditing, and bonding requirements on an individual 

rather than aggregate basis. In our September 2012 report, we noted that 

a number of compliance-related questions were left unanswered for open 

MEPs.51 Additionally, we noted that, for purposes of preferential tax 

treatment, IRS might still consider an open MEP to be one plan rather 

than a series of individual plans. In an effort to remove confusion for plan 

sponsors, we recommended Labor and IRS coordinate their 

interpretations and develop compliance-related guidance. Labor and IRS 

generally agreed with our recommendations on coordination.52

Labor’s expectation is that the recently issued opinions on open MEPs 

will serve as guidance to the pension industry at large. However, despite 

the ruling on open MEPs from Labor, pension experts and MEP 

representatives told us that broader policy questions remain. The opinion 

did not provide Labor’s view on the potential of open MEPs to lower plan 

costs or expand coverage, but we were told by MEP representatives and 

pension experts that open MEPs will continue to receive the attention of 

policymakers for that reason. At this time no one knows for certain how 

many open MEPs there are, who is in them, or how they may affect future 

pension coverage. Pension experts cautioned that any legislative change 

allowing certain open MEPs should ensure that there are appropriate 

safeguards to protect plan participants.

 

50 The PEO representatives we interviewed said their PEOs operated under what they 

referred to as a “coemployer” contract. We did not find coemployer defined in federal 

statute. Because the term PEO is not well-defined either, and the actual services are 

contractually determined, some refer to certain PEO practices as “employee leasing” or 

“payrolling,” which involves providing administrative or financial services to employers, 

rather than serving as an employer in the sense of hiring or supervising workers. 

According to Labor officials, a PEO does not represent a bona fide association but 

establishes an employer relationship with the employees of its clients through the services 

it offers them. 

51 GAO-12-665. 

52 Specifically, Labor and IRS officials said they will amend their coordination agreement if 

compliance issues become more apparent.
 

Page 22 GAO-13-748T 

Labor officials said the potential for inadequate employer oversight of a 

MEP is greater than for other pension arrangements because employers 

pass along so much responsibility to the entity controlling the MEP. Labor 

officials noted that potential abuses might include layering fees, misusing 

assets, or falsifying benefit statements.53 One pension expert agreed that 

there is potential for MEPs to charge excess fees without the enrolled 

employer being aware. While Labor officials acknowledged that single 

employer plans could be subject to similar abuses, they cautioned that 

the way a MEP is structured and operated could make it particularly 

susceptible to abuses.54

Labor’s lack of data to identify different MEP sponsor types or any 

employers participating in MEPs limits the agency’s ability to protect MEP 

employers and participants. To ensure Labor has information needed to 

oversee MEPs, in September 2012, we recommended that Labor gather 

For this reason, the structure of a particular MEP 

can be important. Representatives of MEPs maintained by associations 

we interviewed said they had an appointed board made up of association 

members who served as the named fiduciaries of the plan. Most of these 

associations required board members to also participate in the MEP. 

However, the extent to which open MEPs have or would have such 

structures in place is unclear. Given the limited knowledge some plan 

sponsors have of the fees they pay and their fiduciary responsibilities, it 

would appear that some such governance structure or related safeguards 

is warranted to protect employer and participant interests.

 

53 Under ERISA, an employee pension benefit plan can only be sponsored by an 

employer, an employee organization, or both. A group or association can be considered 

an employer under ERISA if Labor determines the association is bona fide. Under its 

advisory opinions, Labor has long looked at certain factors, such as pre-existing 

relationships among employers, to determine if a group of employers constitutes a bona 

fide association of employers that may, therefore, sponsor a single employer plan under 

Title I of ERISA. Pension and Welfare Benefits Admin., U.S. Dept. of Labor, Advisory 

Opinion 83-15A, 1983 ERISA Lexis 43. Because by definition an open MEP is open for 

any employer to join, without pre-existing relationships or other factors necessary to 

establish a bona fide association, it is not considered an employer under ERISA and 

cannot maintain an employee pension benefit plan. 

54 On April 15, 2013, a former trustee and fiduciary of a number of MEPs was convicted of 

17 counts of wire fraud by a federal jury in Boise, Idaho. The jury heard evidence that the 

individual misappropriated plan assets for his personal use. According to Labor officials, 

sentencing is scheduled for July 31, 2013. Labor officials told us that last year, they 

obtained the appointment of an independent fiduciary who is currently managing the 

remaining plan assets and making distributions. They stated further that the department is 

monitoring the progress of the criminal case, as well as the efforts of the independent 

fiduciary, who they report is actively attempting to recover additional assets. 
 

Page 23 GAO-13-748T 

additional information about the employers participating in MEPs, 

potentially through the Form 5500, which is the primary source of pension 

plan information for government oversight activities.55 Labor officials said 

the number of participating employers or the names of participating 

employers could be useful oversight information. The agencies generally 

agreed with our recommendation on gathering additional MEP-related 

information and said they will consider MEP-related changes to the Form 

5500 as part of their regular evaluations. We consider this an important 

first step, and await any proposed or scheduled changes to data 

collection.

For workers at small employers, building an adequate level of income for 

retirement is becoming increasingly challenging. Particularly for small 

employers, the low level of plan sponsorship means that many of their 

workers may enter retirement with little or no income outside of Social 

Security. Small employers also face some greater challenges to 

sponsorship than larger employers and they often have less time, fewer 

resources and personnel to handle them. The potential advantages of 

multiple employer plan design are appealing in this context, however, 

current data and information, as well as other safeguards, will be

necessary to ensure that small employer interests are protected and 

promises to participants are not broken.

Chairman Harkin, Ranking Member Alexander, and Members of the 

Committee, this completes my prepared statement. I would be pleased to 

respond to any questions that you may have at this time.

 

55 GAO-12-665

Concluding 

Observations 
GAO Contact and Staff Acknowledgments

Page 24 GAO-13-748T 

For further information about this testimony, please contact Charles A. 

Jeszeck at (202) 512-7215 or jeszeckc@gao.gov. Contact points for our 

Offices of Congressional Relations and Public Affairs may be found on 

the last page of this testimony. Tamara Cross, Assistant Director; 

James Bennett, Edward Bodine, Sarah Cornetto, Patrick diBattista, 

Chuck Ford, Gene Kuehneman, David Lehrer, Ted Leslie, Sheila McCoy, 

Thomas A. Moscovitch, MaryLynn Sergent, Roger Thomas, Frank 

Todisco, Kathleen van Gelder, Lacy Vong,and Craig Winslow were key 

contributors to this testimony.

(131267)

GAO Contact and Staff Acknowledgments

GAO Contact and 

Staff 

Acknowledgments 
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