SHORT PLAN YEAR!

[Jilliandiz]

Welfare Plan Filings

Original Plan year is 6/1/03 - 5/31/04

Amending to change plan year as 7/1/04 - 6/31/05

Policy year is also changing w/insurance providers at 7/1/04

File a 5500 for 6/1/03 - 5/31/04

File a Short Plan Year 5500 from 6/1/04 - 6/31/04

File new 5500 from 7/1/04 - 6/30/05

Can you verify for me those are the 5500's that need to be completed???

Also, what would I request from the insurance providers for the Short Year?? Would I request just policy coverage during that time period in the month of June, 2004???

Can someone give me some feedback!!!

Thanks

[Guest Carolyn Barnard]

Whether or not the filings need to be done would depend on the plan's funding and the number of covered participants at the beginning of the plan year. It sounds as though this is a fully-insured plan (since you're discussing policy year changes), so the plan would need to be filed on if there are 100 or more participants at the beginning of the plan year. If employer and/or employee premiums are held in a separately-maintained account or trust outside of the company's general assets, the plan would need to be filed on regardless on the number of participants.

Yes, there would be a short one month plan year filing from 6/1 - 6/30/04. Yes, you should request the Schedule A information from the insurance company for just that one month period.

[E as in ERISA]

You get a Schedule A based on the contract dates, not the plan year. So if you have short contract, you would have an extra Schedule A and attach it the the 5500 that ends at the same period. But if the contract years are different than the plan years, you just attach the Schedule As for the contract years ending within the plan year.

http://www.dol.gov/EBSA/PDF/2003-5500inst.pdf

[Guest Carolyn Barnard]

Katherine is right in a scenario where there is a welfare plan document governing the insured benefits. I'm in the middle of a similar filing situation where there is no plan document and therefore, the insurance policy is the "document" and the policy year determines the filing deadline.