Definition of plan participant

[Guest S Craig]

A group health plan has 70 employees covered on the plan, but 130 covered units.

All information says that a 5500 needs to be filed if there are 100 "participants" or more on the plan.

The DOL (via a phone call) indicates that a "participant" is an employee. The insurance carrier indicates that a participant is a covered member, which makes sense from the insurers standpoint.

Does this group health plan need to file the 5500? Is a plan participant the employee only?

Thanks very much!

[Guest SHaddon]

According to the Plan 5500 instructions...

"For welfare plans, the number of participants should be determined by reference to 29 CFR 2510.3-3(d). Dependents are considered neither participants nor beneficiaries."

The instructions then go on to state who is a participant which includes active employees, retired employees, etc.

So no filing required as plan only has 70 participants.

Hope this helps

[Guest S Craig]

Terrific! Thanks so much!