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5500-SF requirement for self-funded medical ins plan?

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I don't handle health and welfare plans, but a client is asking if a 5500-SF is required for his self-funded medical insurance plan. He has received conflicting advice. One person advising yes, and he needs to go through DFVC for past years and another advising that health welfare plans under 100 participants never have to file a 5500.

I've read and re-read the instructions, and it seems that only unfunded, fully insured or combination unfunded/insured welfare plans with fewer than 100 participants at the beginning of the plan year are exempt from 5500 filing. So I agree with first person's recommendation.

Thanks in advance!

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"Self-funded" does not necessarily mean "funded" in the ERISA sense. Typically self-funded (i.e., self-insured) plans are "unfunded" for 5500 purposes because there is no irrevocable trust holding any plan assets.

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