Calendar year 5500 with multiple off-calendar year H&W benefits

[Guest El Guapo]

A client has approximately 10 different H&W benefits (medical, dental, vision, LTD, etc). With few exceptions, each benefit has a different insurance contract year, all of which are off-calendar. Currently, they bundle all of these benefits into one ERISA plan. The 5500 is based on a calendar year. The insurer for each benefit provides the 5500 information on a calendar year basis (even though the contract years are all off-calendar). The Schedule A for each benefit lists the "policy or contract year" as the same calendar year listed in Part I. Is this permissible?

Instructions on Form 5500 seem to suggest it is permissible, as long as the insurer maintains records for that benefit on a calendar-year basis:

"Information entered on Schedule A should pertain to the insurance contract or policy year ending with or within the plan year (for reporting purposes, a year cannot exceed 12 months).

Example. If an insurance contract year begins on July 1 and ends on June 30, and the plan year begins on January 1 and ends on December 31, the information on the Schedule A attached to the 2011 Form 5500 should be for the insurance

contract year ending on June 30, 2011.

Exception. If the insurance company maintains records on the basis of a plan year rather than a policy or contract year, the information entered on Schedule A may pertain to the plan year instead of the policy or contract year."

[401 Chaos]

May I ask a related / follow-up question. I understand the general rule above regarding Schedule As but how does that run through other sections of the Form 5500. For example, we have large wrap plan that has a Plan Year End of 11/30 but all or nearly all of the insurance policies and component plans operate on a calendar year basis. As a result, the Schedule A info we are supposed to use generally reflects only one month of the actual Plan Year (i.e., the month of December) with 11 months of the Plan Year covered by the following year's Schedule A info. There are some years when we have big changes in enrollment from one year to the next that don't really get captured by the prior Schedule A info. Is that an issue? Is there a way to address?