"Mega" Wrap Document - Participant Count

[Christine Roberts]

Controlled group entity maintains a "mega-wrap" health plan document that covers group health, dental, life insurance, and short and long term disability.

Not all participants are enrolled in each component of the mega-wrap plan. Thus, 500 are enrolled in the life insurance component, 325 in group health, 400 in dental, etc.

What is the total participant count for the beginning and end of the plan year, for Form 5500 purposes?

Do we use the largest number (life insurance) and file an attachment to the Form 5500 showing how many participants are covered under each component of the plan?

[JanetM]

You would count all those eligible for benefits. It gets dicey when you have some opting for some coverage and some for another.

Can you look at largest group and determine if there is any one opting for other benefits who is not included in largest group? If this is not the case, you should count each employee electing some form of benefit. Do not count children, spouses, beneficiaries or anyone entitled to benefits under QMCSO as participant.

One way to fix this is to find one inexpensive coverage and automatically cover entire group. We use various levels of life insurance from $5,000 to two or three times salary.

The rule is in DOL reg section 2510.3-3(d) sorry I can't find a link to it right now.

[E as in ERISA]

Do they have a 125 plan, and can you ballpark it by looking at how many are participating in that? E.g., if there are 250 participating in all three and another 50 participating in only health and life and another 25 participating in health and dental and then another 200 only in life and another 125 only in dental, then there would be 650 paying premiums through the 125 plan?