What is an active participant in a welfare plan?

[Lori Foresz]

I have a copy of last year's data request letter for a Form 5500 for a welfare benefit plan. Our standard letter asks for the number of active plan participants as of the end of the plan year including those who have not elected coverage. I want to change this because even though the instructions are vague, I think only those who have elected coverage (even if they don't actually receive any coverage) should be reported as active participants.

Does anyone agree or disagree?

Thanks!

[JohnCheek]

Agree- for a welfare plan, a current employee who is not covered, and has elected not to be covered, should not be an "active" participant.