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Belgarath

Wrap and "mega wrap" documents

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I've seen wrap documents for Section 125 plans, that allow you to file just one 5500 form for all of the benefits that fall under the 125 plan. I've also just seen reference to a "Mega Wrap" document, which incorporates the cafeteria plan and underlying benefits, in addition to certain health/welfare benefits that are NOT under the cafeteria plan.

Is this a viable technique for doing only one 5500 form? Ignoring document issues, for now anyway  - just interested in the 5500 question. Thanks. 

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Belgarath, I don't know if I can find guidance (hope there's none to the contrary!), but that is the way I have usually done it, i.e. included the 125 "plan" (which is really a tax gimmick, not a plan), the 129 benefit, etc., in one plan document. I have always thought that the DOL would just consider that the non-ERISA benefits as notionally not part of the ERISA plan required to be reported on 5500. You could insert verbiage to that effect in the document if you think would help. Never had any pushback on this approach from DOL or auditors, but maybe others have had different experience and we'll hear from them.

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Belgarath---Agree with Luke --that's the way we've always done it since the early 90s. 

The definition of plan is drafted to include all  applicable

benefits, including the benefit "vehicle" of the 125.

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