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If the employer pays the premiums for the following benefits: Life, AD & D, Long Term Disability, and a cafeteria plan does NOT exist, would a Form 5500 with related Schedule A information have to be filed if the benefits have over 100 participants?

If filing is required, and a cafeteria plan document does not exist, what plan number do you put on Form 5500?

I'm getting confused about filing a Form 5500 and Schedule A information for benefits in a cafeteria plan (when there are more than 100 participants and/or a Trust has been established) as opposed to filing for welfare benefits plans not covered under a cafeteria plan.

Do we need to file if our welfare benefit plans have more than 100 participants and the benefits are not under a cafeteria plan?

Can someone please clarify this for me?

Thank You

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Welfare benefit plans ex. medical, dental vision, etc. are required to file an annual 5500 if they have more than 100 participants. The plan numbers for welfare plans should be 501, 502, 503, etc. Do not use the same number for more than one plan. If the medical plan is 501, the dental plan would be 502. The 5500 filing requirement for welfare benefit plans is independent of your cafeteria plan. Some employers get confused and think they do not have to file a 5500 if they do not have a Section 125 plan. As an example, an employer (no cafeteria plan) with 250 covered employees in a dental plan should file a 5500.

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Thank you for clearing up the filing issue for me.

I am still uncertain about the document issue.

I know that the benefits such as medical, dental, etc. have policies/contract numbers with the insurance carriers, but what about a plan number since this must be reported on Form 5500?

You mentioned that each component is assigned a different number 501, 502, etc., but do they need a document in order to assign a number (other than their policy/contract number).

I am familiar with a cafeteria plan document, where the benefits are listed and the plan is assigned a number such as 501.

Does the same exist for "Non-cafeteria" benefits?

Example: Filing is required for a client's "Non-Cafeteria" welfare benefits of LTD and group term life since they have exceeded the 100 participant threshold. I have the contract/policy numbers for each. Do I just assign #501 and #502 to each benefit respectively or do I need to have a welfare benefit plan document?

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1) answer to first question--yes. These are ERISA H&W benefits, regardless of whether or not a cafeteria plan exists.

2) Plan numbers: Acc & Health (including life) plan numbers start in the 500 series (Pension, 401-k, etc start in the 800 series). Documents are not needed to assign plan numbers, but documents are needed to comply with ERISA disclosure requirements and will reference the plan numbers.

3) If an employer has done a "wrap" plan document, which incorporates all of the H&W benefits, then there will be only one plan # covering all benefits.

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