Abstract...Philippine National Police. GSIS coverage is also limited to life insurance for members...

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FINANCIAL REPORTING PRACTICES OF THE GSIS* Helena S. Valderrama, Ph.D. 1 Abstract The objective of this paper is to assess the compliance by the Government Service Insurance System with the reporting requirements of Philippine Financial Reporting Standards; in particular, PAS 26 Accounting and Reporting by Retirement Benefit Plans and PFRS 4 Insurance Contracts. Assessing the financial health of the GSIS has become more compelling as a result of the amendment of the Salary Standardization Law (RA 6758) in 2008, which authorized significant 34-69% increases in government employees’ salaries from 2009 to 2012. A prerequisite to a reliable assessment, however, are financial statements that “fairly present” the financial condition, performance, and cash flows of the GSIS. Fair presentation follows from compliance by the institution with the relevant Philippine Financial Reporting Standards. Based on an evaluation of the 2005 to 2012 financial statements of the GSIS, the study found that, for the most part, GSIS financial statements are compliant with PFRS. However, material non-compliance is found in the reporting of the fund’s retirement and insurance liabilities. The study also estimated the financial return of membership contributions to the GSIS, excluding the insurance coverage, and found the return to be less than the risk-free opportunity cost of capital. Given the crucial role played by the GSIS in the administration of social insurance in the country and the GSIS’ potential impact on national government finances as a state institution, these are crucial areas for GSIS management to address and improve on now. *Government Service Insurance System 1 Professor and BSP Professorial Chair Holder, Cesar E.A. Virata School of Business, University of the Philippines Diliman. The author gratefully acknowledges the financial assistance of the BSP through its professorial chair donation to the UP VSB. 1

Transcript of Abstract...Philippine National Police. GSIS coverage is also limited to life insurance for members...

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FINANCIAL REPORTING PRACTICES OF THE GSIS* Helena S. Valderrama, Ph.D.1

Abstract

The objective of this paper is to assess the compliance by the Government Service Insurance System with the reporting requirements of Philippine Financial Reporting Standards; in particular, PAS 26 Accounting and Reporting by Retirement Benefit Plans and PFRS 4 Insurance Contracts. Assessing the financial health of the GSIS has become more compelling as a result of the amendment of the Salary Standardization Law (RA 6758) in 2008, which authorized significant 34-69% increases in government employees’ salaries from 2009 to 2012. A prerequisite to a reliable assessment, however, are financial statements that “fairly present” the financial condition, performance, and cash flows of the GSIS. Fair presentation follows from compliance by the institution with the relevant Philippine Financial Reporting Standards. Based on an evaluation of the 2005 to 2012 financial statements of the GSIS, the study found that, for the most part, GSIS financial statements are compliant with PFRS. However, material non-compliance is found in the reporting of the fund’s retirement and insurance liabilities. The study also estimated the financial return of membership contributions to the GSIS, excluding the insurance coverage, and found the return to be less than the risk-free opportunity cost of capital. Given the crucial role played by the GSIS in the administration of social insurance in the country and the GSIS’ potential impact on national government finances as a state institution, these are crucial areas for GSIS management to address and improve on now.

*Government Service Insurance System 1 Professor and BSP Professorial Chair Holder, Cesar E.A. Virata School of Business, University of the Philippines Diliman. The author gratefully acknowledges the financial assistance of the BSP through its professorial chair donation to the UP VSB.

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FINANCIAL REPORTING PRACTICES OF THE GSIS

1 Introduction

The interest in this study was triggered by a happy event. On July 28, 2008, the Philippine Congress passed Joint Resolution 4 authorizing the President to revise the salary levels prescribed in RA 6758 or the Salary Standardization Law. Over the next 4 years, most government employees received salary increases that ranged from 34 to 69%.

The salary adjustments (a.k.a. SSL3) were an even bigger blessing to government employees close to retirement. Retirement benefits in government are based on the average monthly compensation in the last three years of one’s employment. Since the last tranche of the salary increases was granted sometime in the middle of 2012, our colleagues who are due to retire this year and next will be the beneficiaries of pension benefits that would have significantly increased due to SSL3.

The higher pension benefits caused by SSL3 cannot but impact negatively on the financial condition of the Government Service Insurance System, the institution that implements the laws that govern social security and insurance benefits for all government employees. Contributions of the imminently retiring employees were made when their salaries were much lower, and yet the benefits they will be paid will be based on their latest, significantly higher, salaries. This expected performance “dip”, for want of a better term, is expected to correct through time, with continuing members effectively subsidizing the retired and exiting members. Nonetheless, the extent of the impact of SSL3 on the financial health of the GSIS is of important concern to all remaining government employees and to the National Government which by law is the guarantor of all of the GSIS’ obligations to its members.

A prerequisite to a reliable assessment of the financial health of the GSIS, however, are financial statements that “fairly present” its financial condition, performance, and cash flows. Fair presentation follows from compliance by the institution with the relevant Philippine Financial Reporting Standards (PFRS). This study thus aims to determine whether or not the financial statements of the GSIS are fully compliant with PFRS. It also aims to estimate the value of GSIS retirement benefits to government employees who will now pay contributions based on salaries increased by SSL3.

2 Review of Literature and Significance of the Study

Pension systems, including those in the Philippines, have been subject to much study given the important role these play in social security and protection. Recent papers have looked at the state of these systems in emerging and developing economies finding, to the surprise of no one, that reforms are needed to improve their governance, sustainability, and investment policies and

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management.2 Manasan (2009), reiterating and expanding on findings by other authors, identifies the following needed initiatives for the Philippine pension systems: (1) Strengthen the link between contributions and benefits; (2) Improve protection to pensioners; (3) Broaden coverage and promote compliance; (4) Put greater emphasis on the fiduciary responsibility of social security institutions and improve the management of their investment portfolio; and (5) Reduce administrative cost.

The GSIS is perceived to be better managed than its counterpart for private sector employees, the SSS.3 Indeed, in at least one indicator, replacement rate (value of pension as a percentage of salary), the public pension system in the Philippines has been found to be even performing better than its regional counterparts and even some OECD countries.4

Nonetheless, this paper expects to contribute to the discussion by focusing on financial reporting as an element of the governance mechanism of pension funds, particularly in this case, the GSIS. This is also the first attempt to look at the GSIS finances after the significant hikes in government salaries implemented from 2009 to 2012. Moreover, while replacement rate may be higher for the GSIS than for many other pension systems, it is still important to know, from a finance perspective, whether the value of pension benefits recovers at least the opportunity cost of money for GSIS members.

The paper proceeds as follows: Section 3 gives an overview of the functions of the GSIS and its social insurance function, focusing on its retirement benefit program. Section 4 discusses the institution’s financial reporting practices using the financial statements from 2005 to 2012 obtained from the GSIS website and makes a determination of whether or not there is compliance with the relevant reporting standards and rules. Section 5 estimates the returns to a GSIS member’s contributions that are based on SSL3. Section 6 concludes and identifies areas for further investigation.

The ultimate objective of this paper is to inform all stakeholders of this very important government unit of the quality of financial information that is currently being made available by the GSIS, and how this can be further improved to support the institution’s ability to fulfil its mandate.

2 See, for example, Manasan (2009), OECD (2009), Asher (2008), Holzmann et al (2000) 3 Villanueva, M. (2013), GSIS Better Managed than SSS http://www.philstar.com/opinion/2013/10/14/1244972/gsis-better-managed-sss 4 OECD (2009), Pensions in Asia/Pacific: Ageing Asia Must Face Its Pension Problems http://www.oecd.org/finance/private-pensions/46260941.pdf (accessed 21 April 2014)

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3 The Government Service Insurance System

History, Administration, Mandate

Commonwealth Act No. 186 created the GSIS in 1936 to implement the laws that govern the social security and insurance benefits of all government employees. CA 186 consolidated all the then existing pension funds created by previous laws for government employees in the GSIS. Management and governance of the GSIS was entrusted to a Board of Trustees consisting of a General Manager and seven others, all of whom were to be appointed by the President of the Republic of the Philippines. Then as in now, those who sit in the GSIS Board as representatives of government employees (or who are actual members of the GSIS) are a minority. In CA 186, only 3 of the 8 were to come from government employee organizations or associations. In the latest amendment to the GSIS charter (RA 8291), this has been increased to 4, but the total number of board members was also increased to 9. The other 4 seats are allocated to members of the banking, finance, investment and insurance sectors. The remaining seat is for the GSIS President and General Manager who is not required to be a GSIS member upon his appointment.

Various laws are the bases of the GSIS’ mandate, authority, and functions.

Republic Act No. 656 (1951) and Presidential Decree No. 626 (1975) mandated the GSIS to administer the Employees Compensation and State Insurance Fund and the General Property Insurance Fund, respectively

Presidential Decree No. 1146 (1977) and Republic Act No. 8291 (1997) amended CA 186 and enhanced the social security coverage of the GSIS

Republic Act No. 10149 (2011) identifies the GSIS as a government-owned or -controlled corporation (GOCC), particularly a government financial institution (GFI), and prescribes mechanisms to strengthen the governance of all GOCCs

R.A. 10149 requires the 30 biggest government owned and controlled corporations (of which the GSIS is one) to undergo periodic special audits by the Commission on Audit (COA). At a minimum, such special audit is supposed to “make a determination whether (1) the accounting records of the GOCC are complete and in accordance with generally accepted accounting practices and standards; and (2) the statements prepared from the accounts present fairly and comprehensively the GOCC’s financial position and the results of its financial operations.”5

The foregoing prescription, on first reading, seems a redundancy. Under Article IX (D) of the Philippine Constitution, the COA already has exclusive authority to examine and audit the accounts of all government entities, including GOCCs, and submit to the President and Congress an annual report on the financial condition and operation of each. The Constitution also gives the COA the exclusive authority to promulgate the accounting rules and regulations for government entities. The requirement of RA 10149, however, specifies that the goal of the examination includes ascertaining compliance by the GOCCs’ financial reports with generally accepted accounting practices and standards and their fair and comprehensive presentation of the GOCC’s financial position and results of operations. This is language that one finds in the description of the quality

5 RA 10149 Sec. 26

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of financial statements expected of private corporations. RA 10149 complements the COA’s constitutional mandate by ensuring that the goal of the COA audit is not just to check judicious and lawful use of public funds, but to ensure that the GOCCs’ financial reports also comply with the standards of disclosure and completeness that are expected of privately-run entities and that satisfy the governance principles of transparency and full accountability.

The Social Security Functions of the GSIS

From the very beginning, membership of most government employees in the GSIS was made compulsory6. The amounts of mandatory contributions (employees’ and employers’ shares) of and benefits to be received by GSIS members were, and continue to be, fixed by law.

Based on RA 8291, GSIS members enjoy the following social security benefits:

1. Separation 2. Retirement 3. Permanent disability benefits 4. Funeral benefit 5. Life Insurance 6. Optional insurance – life, health, hospitalization, education, memorial plans

The law also prescribes that all contributions of GSIS members from which the benefits for items 1 to 5 above are to be paid, together with earnings and accruals, are to go to the GSIS Social Insurance Fund. The GSIS is required to manage this fund separately from the other funds it was required to administer by other laws. As can be seen in Chart A below, the Social Insurance Fund is the biggest fund managed by the GSIS.

Chart A

6 Membership in the GSIS is not compulsory for members of the Armed Forces of the Philippines and the Philippine National Police. GSIS coverage is also limited to life insurance for members of the judiciary and the Constitutional Commissions.

98% (P588.2 billion)

1% 0%

0% 1%

GSIS FINANCIAL RESERVES as of 31 Dec 2012

Social insurance fund

Optional life insurancefundPre-need insurance fund

Employees compensationinsurance fundGeneral insurance fund

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The Social Insurance Fund (SIF) is broken down based on the benefits to be paid out from it. Chart B shows the SIF break down as of 31 December 2012.

Chart B

GSIS members contribute 21% of their monthly compensation (9% employee’s share + 12% employer’s share) to the SIF. Four percent of the 21% go towards the life insurance coverage of the member; the rest are for the employee’s retirement benefits (see screen shot from GSIS website below).

Source: http://www.gsis.gov.ph/default.php?id=86 (accessed 19 April 2014)

Upon retirement, a member’s benefits are based on his/her revalued average monthly compensation (RAMC) that is computed as follows:

Old age benefits

74%

Policies in force 11%

Survivorship benefits

12%

Disability benefits

2% Burial benefits

1%

Contingencies 0%

GSIS Social Insurance Fund as of 31 December 2012

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RAMC= P700 + Average Monthly Compensation or AMC; where AMC is the total monthly compensation received by the member during the last 36 months of service divided by 36.7

The member’s monthly pension upon retirement also depends on his length of service to government, and, per RA 8291, is computed as follows:8

1) thirty-seven and one-half percent (37.5%) of the revalued average monthly compensation; plus

2) two and one-half percent (2.5%) of said revalued average monthly compensation for each year of service in excess of fifteen (15) years: Provided, That the basic monthly pension shall not exceed ninety percent (90%) of the average monthly compensation.

Social insurance constitutes the biggest source of revenues and expenses of the GSIS, as can be seen in Charts C and D below.

Chart C

7 Retirement Under RA 8291 (http://www.gsis.gov.ph/default.php?id=33) in Attachment A 8 Section 9

Social insurance contribution 53% (P73.3B)

Insurance premium

5%

Other insurance revenue

0%

Revenue from loans and

receivables 14%

Revenue from investments

25%

Revenue/(loss) from investment

property 1%

Other revenue 2%

CY 2012 Revenues of the GSIS

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Chart D

4 The Quality of Financial Reporting of the GSIS

Reporting Standards

This study did not come across a clear pronouncement of what set of accounting standards the GSIS is to comply with. As already mentioned, the Philippine Constitution gives the Commission on Audit the authority to prescribe accounting rules and regulations for government entities, including GOCCs. However, the COA-promulgated New Government Accounting System (NGAS) seems to apply to Government Agencies and Local Government Units, rather than to GOCCs. In its 2012 Annual Report to President Aquino and to the Heads of Congress, the COA describes GOCCs as having adopted “varied” frameworks in the preparation and presentation of their financial statements, including “Philippine Financial Reporting Standards, the accounting principles generally accepted in the Philippines, and the accounting principles enunciated under the New Government Accounting System (NGAS)”.9

Nonetheless, in Note 2.1 (a) of its 2012 audited financial statements, the GSIS stated that its reports are compliant with Philippine Financial Reporting Standards (PFRS). In her Audit Certificate on the said GSIS report, COA Auditor J. Moreno rendered an unqualified opinion, stating that the GSIS financial statements “present fairly, in all material respects, the financial position of the GSIS and its subsidiary as at December 31, 2012 and its financial performance and its cash flows... in accordance with Philippine Financial Reporting Standards.” (emphasis added) This study thus uses the standards and requirements of PFRS in assessing the quality of financial reporting of the GSIS.

9 COA, 2012 Annual Financial Report: Government Owned and/or Controlled Corporations Vol. II-A, p4.

Claims/ benefits from

social insurance

84% (P63B) Claims/benefits from other insurance programs

3%

Other expenses 1%

Insurance expenses

3%

Personal services

4%

Operating expenses

5%

CY 2012 Expenses of the GSIS

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The Standard of Fair Presentation

“Fair presentation”, as defined, in PFRS,10 requires not just compliance with the recognition and measurement rules of assets, liabilities, income and expenses of the reporting entity in accordance with applicable PFRS, but provision of needed disclosures that will enable users “to understand the impact of particular transactions, other events and conditions on the entity’s financial position and performance.”11

Quoting from the standard:

“Fair presentation requires the faithful representation of the effects of transactions, other events and conditions, in accordance with the definitions and recognition criteria for assets, liabilities, income and expenses set out in the Framework. The application of IFRSs, with additional disclosure when necessary, is presumed to result in financial statements that achieve a fair presentation.”12

In assessing the quality of GSIS’ financial reports, therefore, the first step is to identify the specific standards that should be used in accounting for the transactions, products, and services of the reporting entity. Given that the GSIS’ major functions are the management of the retirement benefits fund of government employees and the offering of insurance services to its members and other government entities, these standards are determined to include (1) PAS 26 Accounting and Reporting by Retirement Benefit Plans13 and (2) PFRS 4 Insurance Contracts.

The Reporting of Assets, Liabilities, Expenses and Reserves (Net Assets Available for Benefits) of the GSIS14

Users of the financial statements of the GSIS are most interested in determining the quality and sufficiency in value of its assets and reserves to address its current and future obligations. Users are also interested to know the level of operating costs of the entity to ensure that the GSIS’ resources are being used judiciously and efficiently. Thus, this study focused on the reporting of GSIS’ assets, liabilities, reserves, and expenses.

The GSIS management is to be credited with providing detailed disclosure regarding the assets of the funds (see Chart E). The valuation of the assets is in accordance with PFRS; and there

10 Philippine Accounting Standards (PAS) and Philippine Financial Reporting Standards (PFRS) promulgated by the Financial Reporting Standards Council are identical to International Accounting Standards (IAS) and International Financial Reporting Standards (IFRS) issued by the International Accounting Standards Board and its predecessor, the International Accounting Standards Council. 11 PAS 1 para 15 and 17 12 PAS 1 para 15 13 PAS 26 para 7 explicitly excludes “government social security type arrangements” from the scope of the standard. This is likely due to the fact that IAS/IFRS have mostly focused on the financial reporting requirements of profit-oriented entities. However, there is currently no other standard that can be used to evaluate the reporting of the GSIS’ retirement benefits plan. Moreover, the GSIS identifies no other standards that it used to prepare its financial statements other than PFRS. 14 See Attachment B for a table showing the definition and measurement bases of important assets, liabilities, reserves, revenue and expense accounts of the GSIS.

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is a breakdown of the kinds of loans granted and financial asset investments of the fund in the notes to the financial statements. Very commendably, the GSIS also provides compliant and informative disclosures on the various financial risks the entity’s assets are exposed to and how it is managing those risks.

Chart E

This researcher also does not find exception to the way the GSIS accounts for its expenses. The notes provide a detailed breakdown of all expenses by nature as required by PFRS. As can be seen in Chart F below, GSIS has managed to keep its personal and maintenance and other operating expenses relatively stable for the past 8 years despite significant increases in its revenues. By law, the GSIS is allowed “a maximum expense loading of 12% of yearly revenues from all sources”15 and management reported that this ratio was just 3.5% in 2012. Impairment losses were excluded in the computation of the expense loading, however, and this researcher does not find tenable management’s arguments that this was done because impairment losses are “extraordinary” and “non-cash” in nature.

15 RA 8291 Sec. 35

Cash and cash equivalents

5%

Premiums and loans receivable

- net 30% Investments in

Financial Assets 57%

Property and equipment - net

1%

Investment property

4%

Other assets -

net 3%

GSIS Assets as of 31 December 2012

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Chart F

It is in the reporting of reserves and liabilities that this study finds the following violations:

1. There is no disclosure of the “actuarial present value of promised retirement benefits, distinguishing between vested benefits and non-vested benefits”, as required by PAS 26 para. 17. It is noted that the GSIS discloses “actuarial reserves” in its notes to the financial statements; however, as the entity itself explains, actuarial reserves include an estimate of the future value of future contributions/net premiums and thus is a lower amount than the actuarial present value of promised retirement benefits which is what the standard requires to be disclosed.

Actuarial reserves are not shown on the face of the Statement of Financial Position of the GSIS. Net assets for the GSIS consist mainly of “financial reserves”, unrealized gain on investments, and surplus. “Financial reserves” are the “amounts set aside and appropriated from the surplus of a fund to ensure the payment of future obligations as estimated by actuarial reserves”16

Data from 2005 show that sufficient financial reserves could be set up for the SIF’s actuarial reserves up to 2010. In 2011 and 2012, actuarial reserves have exceeded financial reserves (see Chart G). This is likely an effect of SSL3 on the SIF.17

16 2012 Annual Report, Note 16 of the Notes to the Financial Statements, p43. 17 It is noted that, as of 31 Dec 2012, the GSIS reported unrealised gain from financial assets in surplus that is sufficient in amount to eliminate the SIF’s financial reserve “deficiency” on that date.

-

20,000

40,000

60,000

80,000

2005 2006 2007 2008 2009 2010 2011 2012

GSIS Personal Expenses and MOOE vis-a-vis Social Security Contributions

& Net Revenue from Loans and Investments

Personal expenses MOOE

Net revenue from loans and investments Social insurance contributions

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Chart G

2. GSIS accounts for its various insurance funds in a similar manner to the Social Insurance Fund. Actuarial reserves are estimated and financial reserves are appropriated from surplus and reported as part of Net Worth in the Statement of Financial Position. This treatment is not consistent with PFRS 4 Insurance Contracts. PFRS 4 para 15 states: “An insurer shall assess at each reporting date whether its recognised insurance liabilities are adequate, using current estimates of future cash flows under its insurance contracts. If that assessment shows that the carrying amount of its insurance liabilities... is inadequate in the light of the estimated future cash flows, the entire deficiency shall be recognised in profit or loss.”

It can be argued that, for most of the insurance funds the GSIS manages, actuarial reserves, which is an estimate of the insurance liability of the GSIS equals the financial reserves reported in the Statement of Financial Position. The nature of an estimated liability, however, is completely different from an appropriation of surplus. Moreover, changes in the estimated liabilities have not been reported in GSIS’ Statement of Comprehensive Income as required by PFRS 4.

5 Estimating the Returns on GSIS Contributions Under SSL3

It has been observed that retirement benefits of government employees under GSIS are significantly higher than those received by private-sector employees under the SSS. However, it should also be noted that government employees contribute, as a percentage of their monthly salary, around double the amount contributed by their private sector counterparts.

-

100,000

200,000

300,000

400,000

500,000

600,000

700,000

2005 2006 2007 2008 2009 2010 2011 2012

Actuarial Reserves and Financial Reserves of the Social Insurance Fund

SIF Actuarial Reserves

SIF Financial Reserves

Linear (SIF Actuarial Reserves)

Linear (SIF Financial Reserves)

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An important question for both SSS and GSIS members is this: excluding the insurance component of the benefits, what level of financial return does a member earn for the contributions he/she made to the fund? This study estimates this return for GSIS members.

The assumptions of the simulation are as follows:

1. Member starts making contributions at age 24, and does this continuously until the compulsory retirement age in government of 65.

2. The member starts at SG 16 (P28,080/month). This is the starting SG of an Instructor IV at the UP Virata School of Business and, consistent with GSIS actuarial assumptions, the member enjoys a 5% salary rate increase annually.

3. Upon retirement, the member chooses the 18month lump sum + immediate monthly pension option. The basic monthly pension is pegged at the ceiling of 90% of the average monthly compensation.

4. The member retires “permanently” at age 70. Based on the World Health Organization, as of 2012, the life expectancy at birth is 65 years for Filipino men and 72 years for women.

The approach is to estimate the rate at which the future value of the monthly contributions of the GSIS member (excluding the 4% portion for life insurance) equals the value of retirement benefits at his/her retirement. The latter is computed on a present value basis (to the date of retirement) using a discount rate of 3.507%, the 5-year ROP yield as of 15 April 2014.

The simulation shows that the value of GSIS retirement benefits is equivalent to a 3.77% return on the monthly contributions of the member. This approximates the average year on year inflation rate in the last 5 years, and compares unfavourably with the 25-year ROP, which had a yield of over 5.4% last 15 April 2014.

The return worsens if the member chooses the 5-year lump sum option, and improves considerably if the member lives up to age 75 (see table below).

Option 1 (5 year

lump sum) Option 2 (18 month

lump sum) Base Assumptions 2.53% 3.77% If member lives to 75 y.o. 5.56% 6.25%

6 Concluding Remarks

This paper looked into the financial reporting practices of the GSIS and sought to determine the financial return of a member’s social security contributions. As mentioned in the introduction, the financial health of the GSIS is of concern not only to its members but to all taxpayers due to the sovereign guarantee included in the enabling law of the entity. Credible financial statements are needed for a proper assessment of the GSIS’ financial health.

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The study finds that, for the most part, the financial reporting practices of the GSIS are compliant with Philippine Financial Reporting Standards. GSIS management is also to be commended for the detailed and informative disclosures on the fund’s assets, revenues, and expenses. Areas for correction, however, include the reporting of the GSIS’ estimated liabilities relating to its issued insurance contracts and members’ retirement benefits. The COA audit certificate makes mention of these matters, although they were not identified as exceptions but rather as items for “thorough study for proper presentation in the financial statements.”

Another issue this paper explored is the rate of return on a member’s mandatory social security contributions. It is shown that if a member does not exceed the life expectancy age, the financial return on his contributions is less than the opportunity cost of capital as measured by the risk-free rate. The simulation can be improved by excluding the cost of disability insurance from the contributions; but initial attempts to do this show that the returns do not improve significantly even if disability benefits are considered.

In the course of this study, two questions keep popping up in the mind of the researcher that are important areas for further study: to what standards of performance should the GSIS be held? To whom should the GSIS be principally accountable?

The GSIS does not have a regulator in the same way that private sector entities performing the same functions do. RA 8291 included a provision that authorized the Insurance Commission to make an examination of the financial condition and methods of transacting business of the GSIS at least once every three (3) years, but this is not the same as putting the GSIS under the supervision and control of the Insurance Commission. GSIS members are “captive” in the same sense that small electricity consumers within a franchise area are; to ensure their interests are protected, a clear regulator for the GSIS (and the SSS) should be seriously considered.

All funds of the GSIS have come from contributing members. Except for the sovereign guarantee which is theoretically not necessary if GSIS funds are managed well, the National Government has no financial stake in the institution. Yet, in the governance structure of the GSIS, all members of the Board are Presidential appointees, and, as already noted, representatives of the members are a minority. It is not clear who the members of the banking, finance, investment and insurance sectors are supposed to represent and whose interests they are or will be serving in the Board. How can contributing members hold the GSIS Board of Trustees accountable to them?

There are many positive observations that can be made of how GSIS has been managed in recent years, including in the area of financial reporting. Nonetheless, there are clear areas of improvement as well. Reforms of the pension fund systems of the Philippines have to continue.

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References

Asher, M. 2000. Social Security Reform Imperatives: The Southeast Asian Case http://workspace.unpan.org/sites/internet/documents/UNPAN92498.pdf (last accessed 21 April 2014)

Holzmann, R., I.W. Mac Arthur, and Y. Sin. 2000. Pension Systems in East Asia and the Pacific: Challenges and Opportunities. Social Protection Discussion Paper Series 0014. Washington, DC: World Bank. http://siteresources.worldbank.org/SOCIALPROTECTION/Resources/SP-Discussion-papers/Pensions-DP/0014.pdf (last accessed 21 April 2014)

International Accounting Standards Board (IASB), IAS 26 Accounting and Reporting by Retirement Benefits Plans and IFRS 4 Insurance Contracts

Manasan, R. 2009. A Review of Social Insurance in the Philippines. Philippine Journal of Development No. 67 Vol. 36, No. 2.

OECD. 2009. Pensions in Asia/Pacific: Ageing Asia Must Face Its Pension Problems http://www.oecd.org/finance/private-pensions/46260941.pdf (last accessed 21 April 2014)

www.gsis.gov.ph

www.coa.gov.ph

www.who.int

www.census.gov.ph

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Attachment A – Retirement Under R.A. 8291

When availing of the retirement program under RA 8291, only two things should be considered: age and the length of service.

To qualify for this retirement mode:

1. The retiree must have rendered at least 15 years of service and must be at least 60 years of age upon retirement.

2. He /she must not be a permanent total disability pensioner.

Unlike other retirement modes, the last three years of service of a retiree need not to be continuous under RA 8291

Packages in store for you

Retiring members who will opt to retire under RA 8291 are entitled to either of the following:

Option 1: 5-Year Lump Sum and Old Age Pension

Under this option, the retiree can get his/her five-year worth of pension in advance. The lump sum is equivalent to 60 months of the Basic Monthly Pension (BMP) payable at the time of retirement. After five years, the retiree will start receiving his/her monthly pension.

Option 2: Cash payment and Basic Monthly

In option 2, the retiree will receive a Cash Payment equivalent to 18 times the Basic Monthly Pension (BMP) payable upon retirement and then a monthly pension for life payable immediately after his retirement date.

The BMP is computed as follows: a) If length of service is less than 15 years: BMP = .375 x RAMC (Revalued Average Monthly Compensation) b) If length of service is 15 years and more : BMP = .025 x RAMC x Length of service The BMP, however, shall NOT exceed 90% of the Average Monthly Compensation (AMC). RAMC stands for Revalued Average Monthly Compensation and is computed as follows : RAMC= P700 + AMC (Average Monthly Compensation) AMC = Average Monthly Compensation = Total Monthly Compensation received during the last 36 months of service divided by 36

Source: http://www.gsis.gov.ph/default.php?id=33 (last accessed 19 April 2014)

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Attachment B – Accounting Policies on Selected Financial Accounts of the GSIS based on the 2012 Notes to the Financial Statements

Accounts from the Statement of Financial Position

Account Title Definition Measurement Basis

Loans receivable loans granted to members, government agencies and private entities

amortized cost; net of allowance for impairment loss

Financial assets

Held for Trading (HFT), Available for Sale (AFS) and Held to Maturity (HTM) securities; as of Dec 31 2012 consisted mostly of ROP notes and bonds (70%), traded stocks (20%), externally managed funds (5%), corporate bonds (3%)

HFT measured at fair value, with changes taken to profit or loss; AFS measured at fair value with changes reflected in other comprehensive income (surplus); HTM measured at amortized cost

Derivative instruments

deliverable and non-deliverable currency forwards and swaps

fair value, with changes in fair value recognized in profit or loss

Investment properties

land or building or part of a building or both, held to earn rentals or for capital appreciation or both; includes foreclosed real properties; as of 31 Dec 2012, consisted mostly of real properties subject to mortgage loan, commercial-industrial loan, or lease purchase agreement to corporations which were foreclosed or acquired through dacion en pago due to non-payment (59%) and cancelled deeds of conditional sale (33%)

fair value, with changes in fair value recognized in profit or loss

Insurance liabilities

consist mostly of claims due to members/policyholders that remain unpaid as of year end (58.4% in 2012)

Amount payable

Financial reserves

amounts set aside and appropriate from the surplus of a fund to ensure the payment of future obligations as estimated by actuarial reserves;

any increase in actuarial reserves are recorded as financial reserves to the extent of the accumulated earnings net of budgeted expenses (excluding claims) for the following year

Surplus Net operating revenues less increase in financial reserves, plus other surplus (including unrealized gain in investments)

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Accounts from the Statement of Comprehensive Income

Account Title Definition Measurement Basis

Revenue from insurance contributions

Consist mostly of mandatory contributions provided in RA 8291 (96% in 2012)

recognized as contributions become due; premiums on life insurance policies are earned as consideration for the risks/contingencies insured by the GSIS for the benefit of the members and their beneficiaries

Expenses

Consist mostly of claims and benefits (86.5%), operating expenses (4.8%), and personal expenses (4.3%) [note: percentages for CY 2012]

recognized upon utilization of the service or at the date they are incurred

Source: Audited Financial Statements of the GSIS for CY 2012 (www.gsis.gov.ph)

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