5500Nerd

For a health and welfare Form 5500, I have a group that was under a collectively-bargained agreement at the beginning of the year. However by the end of the Plan year, they were not. Is the collectively-bargained box on the 5500 still to be checked?

Hello, I asked my DOL contact awhile back and was told : IRS Notice 2020-23/Covid 19. There is room to type this all out.

Thank you so much for this information. I greatly appreciate this!

I have been monitoring both the IRS and DOL/EBSA websites to see if any special extensions will be given towards the Form 5500s. I realize that this not a natural disaster such as hurricane; never the less our situation with Covid 19 has brought many businesses to a complete stop. Has there been any hint of a special extension?

Hello, VSP (as well as other carriers) report on their Schedule As as if the contract is experienced-rated even though the contracts are confirmed non-experienced. This is causing a bit of confusion and frustration for the Plan Sponsors. Delta Dental use to conduct their Schedule As in this manner and have since reverted back to just reporting the premiums, commissions, etc for non-experience. By chance has VSP made any declaration on why they have switched their approach? Any insight would be greatly appreciated.

Thank you! Question for you- if employee contributions are involved could the situation still be deemed unfunded (due to technical release 92-01)?

Hello, We have several health and welfare plans that are unfunded - benefits paid solely from general assets with the exception of employee contributions. We have one attorney that declares that a SAR is not required because of Technical Release 92-01 - EE contributions if paid to the carrier within 3 months they are not plan assets. We have another attorney who disagrees and says that even with Tech. Release 92-01 the SAR is required because it is not funded 100% from general assets. I have not heard back from the DOL's Office of Regulations and Interpretations. Any thoughts if a SAR should or should not be issued? Many thanks for your consideration.

This information has not been relayed to me. It is not under a trust, however, could a SL still have the Plan participants as the insured instead of the Employer?

I fully agree this does not sound right. I only prepare the 5500s though; the client's actions are beyond my control.

In preparing a health and welfare Form 5500, I only include a Stop Loss Schedule A if the plan is under a trust since the stop loss benefit supports the Plan. For a Plan not under a trust I do not include a Schedule A since Stop loss is an employer benefit, not an employee benefit. However, would a Stop Loss Schedule A be included in a 5500 that is not under a Trust, with the funding from employee contributions. The Stop loss benefit is included in the Plan Sponsor's Wrap Plan Document and SPD. I have never heard of this scenario in the past. I am inclined to include in the Form 5500; however I am not confident. Thank you for your help!

Thanks so much. The DOL noted to file as a single employer plan.

I wondered if anyone ran into the following scenario. An employer enrolled in a Trust Benefit Plan and as a result is a participating employer. The trust declined to file the Form 5500 (reasons unknown) and the participating employer is concerned of being out of compliance. Since the Trust's Plan Administrator refused to file the 5500, the participating employer will file a 5500 for just its employees/enrolled participants. The Participating Employer plans to file as a single employer. The question though is - Would this be the correct path? The assumption is that the 5500 could not be listed under a trust since the Participating Employer is not connected directly to the financials and no knowledge of the Plan Assets. Your thoughts? Your help is greatly appreciated (by the way, the DOL has been asked via voicemail; currently there is no response.

The broker is asking if a Schedule A should be collected. The plan is fully-insured.

The health advocacy type benefits seem to be in a grey area to include a Schedule A or not. This benefit conducts the following: helps locate providers, addresses errors on bills/claims, answers questions on coverage, and asissts with denials and appeals. Would you include a Schedule A? (Plan Documents and SPD not available for referencing). Many thanks for your assistance!

Hello, Has anyone seen any release information on the 2017 Form 5500. Ideally the release would be from the DOL and/or the IRS. As far as I can surmise, there are to be small changes. I found one article from ASPPA, a creditable source; however the article was written in April, 2017. I hoped to have information that is more recent. Link to article: https://www.asppa.org/News/Article/ArticleID/8532 Many thanks for your help and input!

Thanks so much for this insight. I greatly appreciate your help.

I have a client that has had a MEWA since 2008. They never filed the Form M1. They wanted to know of examples of penalty fees others have faced in similar situations on filing Form M1s late. Any input would be greatly appreciated. The DOL will only state what could happen on the fees. Many thanks for your help.

I have a client that has a non-calendar year ERISA Plan (7/1 -6/30) that is a Mega-Wrap Plan (all benefits bundled under one Plan). One of the benefits is the healthcare FSA. It is on a calendar year. I was told that the FSA Plan is not deemed as a policy and cannot be bundled with an ERISA Plan if the Plan Years don't match. I could not find any written provisions to back this up. Any feedback would be greatly appreciated. Many Thanks!