Schedule C for Self-Funded Health Plan

[J Simmons]

Schedule C, Service Provider Information, only calls for information about PLAN payments to service providers.

The sole source of funding for a self-funded health plan in the context of a cafeteria plan (per the DoL exemption to the trust requirement) is the employer's general assets. Service providers to the plan are also paid out of that same source, the employer's general assets.

Is a Schedule C to the F5500 for the plan required to report the payments to the service providers since they were made out of the same funding source as health claims, albeit the employer's general assets?

Or may a Schedule C be omitted from the F5500 filing taking the position that the employer, not the plan per se, paid those service providers?