There were updates to the Form 5500 Schedule H, for the 2020 plan year with the anticipation of the implementation of SAS 136, including updates to the Accountant’s opinion section. There has not been guidance issued related to how to complete this section for firms not early adopting SAS 136. However, during the 2021 AICPA Employee Benefit Plan conference, the Chief Accountant of the Department of Labor, Michael Auerbach, noted that for limited scope audits, the DOL prefers filers complete this section by checking the “unmodified” opinion under Part III question 3a and checking box “(1) DOL Regulation 2520.103-8” under question 3b.