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Is Filing required if Disability Plan not under Cafeteria Plan-Paid by Employer with > 100 Participants?

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We currently have a client that is inquiring whether her prior TPA should have filed form 5500 for their disability welfare benefit plan if more than 100 participants were enrolled.

The disability plan premiums were paid 100% by the employer.

The disability plan was not under a cafeteria plan arrangement.

This could go back as far as 2003 to about 2011.

Would a filing have been required if the employee did not pay for any part of that premium?

I would appreciate your guidance with this.

Thank You,

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