5500 Schedule C for Health Plans

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TPA Administrative fees and stop loss brokerage commission and net stop loss premiums are billed to and paid by employer, net premium is sent to stop loss carrier, so their schedule A does not include broker commission. TPA pays the broker commission to the broker. Is this reportable on the schedule C as an indirect payment, or does the general rule below apply?

Q-3. Will Schedule C disclose plan expenses which an employer pays directly?

No. Schedule C discloses administrative expenses which the plan pays, directly or indirectly. Schedule C will not disclose an expense which the employer pays directly, and for which the plan does not reimburse the employer. If, however, the plan reimburses the employer for an expense payment, show the expense as a direct payment by the plan to the service provider.