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One 5500 or two


Guest tlc@cra
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Guest tlc@cra

A company has a welfare benefit plan with over 100 participant that they have filed a 5500 in the past. During an in house audit, found they did not include the reporting of their dental reimbursement benefit in the filing. This benefit does not have a written document but is mentioned in the employee handbook and is available to all participants. The information on the 5500 is for the welfare benefit plan that does have a plan document. The Question is should the 5500 just be amended to include to include this benefit and would there be a penalty involved or since this benefit is not mentioned in the welfare benefit plan document would this be a separate plan all together and a separate filing altogether need done. I have very little experience with welfare benefit so please forgive me if this is an elementary question.

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The answer depends on how you define the plan. If the welfare benefit plan includes the dental reimbursement benefit, one Form 5500. If it does not, then two. My answer does not help because your problem is determining what constitutes the welfare benefit plan and you do not have clear documentation to answer that question. Or you have clear documentation and you don't like the implications. You have to start with determining what constitures the plan document for the welfare benefit plan and then look at its terms. But the plan document for the welfare benefits plan may be composed of separate writings, one of which is a portion of the employee handbook.

The most likely easy conclusion is that you have two plans, based on a very simple view of what constitues the welfare benefits plan document. If you want another answer, you need more sophisticated help.

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You might want to ask your legal counsel if you can file an amended 5500 and, if the dental is insured, attach a Schedule A for the dental. Then amend your plan document to say "and dental" wherever it says "health," as appropriate. Do the same for your HIPAA policies, etc. if applicable.

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If you want another answer, you need more sophisticated help.

Qdrophile, did you mean sophisticated in the sense of:

a) made complicated or complex; or

b) altered deceptively;

...or did you purposefully prefer to leave it open to private interpretation?

...but then again, What Do I Know?

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