SAR's for welfare benefit plans

[Belgarath]

I'm looking at a bunch of welfare benefit plans for which it appears that SAR's have not been done.

I'm not aware of any guidance that says you don't have to do a SAR for these plans. Is there something I'm missing?

[leevena]

I agree with you, ERISA clearly states that summary annual reports are to be made available automatically each year.

Here is a link to the DOL site. http://www.dol.gov/dol/topic/health-plans/planinformation.htm

[Chaz]

I don't have time to look it up, but I believe that there is an exception from the SAR requirement for unfunded, self-insured plans (regardless of size). That makes sense because most of the SAR language concerns insurance information.

[Belgarath]

Sorry - I probably should have specified that these all have more than 100 participants and are required to file 5500 forms.

So are you perhaps are talking about the possible 5500 exception under 100, etc.?

However, as I look at it, you are probably talking about the exceptions in 2520.104b-10(g). I'll have to look into this, and thanks for bringing it up.

[leevena]

Sorry - I probably should have specified that these all have more than 100 participants and are required to file 5500 forms.

So are you perhaps are talking about the possible 5500 exception under 100, etc.?

I was just saw these posts, and that 's what I was thinking too. I am under the impression that groups above 100, that are required to file 5500's are required to do SAR's.

[Belgarath]

Chaz - yes, you are correct - one of the exceptions in 2520.104b-10(g) is for a welfare benefit plan as you describe, under 2520.104-44(b)(1)(i). None of the other exceptions listed could apply in the situation I'm looking at.

While this doesn't help much in this situation, as nearly all of the plans in question have insurance, it might exempt a couple of them. Thanks again!

[Chaz]

I was just saw these posts, and that 's what I was thinking too. I am under the impression that groups above 100, that are required to file 5500's are required to do SAR's.

The unfunded, self-insured plan exception applies regardless of the size of the plan or whether they have to file 5500s.

[leevena]

I was just saw these posts, and that 's what I was thinking too. I am under the impression that groups above 100, that are required to file 5500's are required to do SAR's.

The unfunded, self-insured plan exception applies regardless of the size of the plan or whether they have to file 5500s.

Did not know that, thanks so much.