Wrap-around document for filing 1 5500 for a cafeteria plan and its co

[CTipper]

I am looking for some help in finding a sample document for a wrap-around plan document that will allow you to file 1 Form 5500 for the Cafeteria Plan and its component welfare benefit plans. How detailed do they have to be? Does the Plan Sponsor have to list each and every welfare benefit by name? Or, can you simply refer to "all benefits offered by the Employer?" I am presuming that the contents of the wrap-around document are relatively brief and can be incorporated into the Cafeteria Plan document itself.

[SLuskin]

EBIA provides an example in their ERISA guide. You can contact them at www.ebia.com.

[Moe Howard]

I would think that your main problem is not going to be how to cram all the Sec 125 & separate welfare benefit plan contents into one plan document .... but rather how are you going to enter on "one" page 2 Form 5500 - lines 6, 7a, 7b, 7c, and 7d numbers of participants in different plans. Such a problem will exist when the employer has more than one welfare benefit plan and each plan has a different number of participants. Remember that Form 5500 is now machine read and handwritten notations in the margins (to DOL or IRS) to explain things are not allowed anymore.

[CTipper]

Interesting thought. I was operating under the assumption that the numbers we put on page 2 would be similar to the numbers that we put on the Schedule F for a small cafeteria plan. If someone is eligible to participant in any of the benefits they are eligible even if they haven't met the eligibility for, say, MFSA yet. Also, the instructions for question 7 say "covered by a plan." Where are we instructed to answer question 7 individually for each component plan?

[Moe Howard]

All welfare benefit plans do not have the same eligibility requirements.

For example: An employer might offer fully insured medical and fully insured disability to its employees. These are two separate welfare benefit plans that are offered (by employer) to employees on a pre-tax basis. Combining these two separate welfare benefit plans into one single "plan document" does not result in one plan, for purposes of completing line 7 of Form 5500. (ie: 20 employees might meet the eligibility requirements of the medical plan ... while 50 employees might meet the eligibility requirements of the disability plan. This would require two separate Forms 5500).

If each of your welfare benefit plans have the same eligibility requirements, then you are correct in thinking that you can file one Form 5500 for both plans and one single Schedule F (if all the benefit plans are pre-tax).