Employee Assistance Plan- any 5500 schedules required?

[britoski]

Does anyone out there an EAP provider (or work with one)? Are you gearing up to provide the enhanced schedule C information to your clients? Alternatively, do you have an EAP provider? Are you requesting Schedule A or Schedule C information?

I have been talking to an EAP client who is trying to determine its obligations to provide information to its clients for 5500 reporting. The services the EAP provides are probably subject to ERISA (due to providing some counseling services) but the client is not an insurance company (thus no Schedule A). Most, if not all, of the client's clients pay for the EAP services out of general assets and no plan assets are typically used (thus, no Schedule C).

I suppose it is possible that a client could adopt a very unusual plan design that would result in plan assets being used to pay for the EAP services, but I think that possibility is probably remote. Consequently, I think the EAP provider's obligations to provide information are probably pretty low. Any thoughts on this?