Participant Count - Beginning and End of Plan Year

[bort]

If you have less than 100 participants at the beginning of the plan year, but over a 100 at the end - do you still have to file the regular 5500? This is for fully insured welfare benefit plans.

Since the 5500 has a line for number of participants at the end of the plan year, this has made me unsure.

[ETA Consulting LLC]

It's based on the beginning. You should also familiarize yourself with the 80-120 rule. Basically, if you are already on a Small-Plan Form, then you won't be required to switch to a Large-Plan Form until your Beginning Count exceeds 120.

Good Luck!

[GMK]

Splitting hairs, the rule is that if you are over 100 but under 121, you can file the same format (small plan or large plan) form that you filed last year.

For fully insured welfare plans, however, you don't file a 5500 when you're under 100, so I believe that you file the large plan form when you're over a 100. But no audit, I think.

[rcline46]

HMMMM, for the participant count to increase during the year, you would have multiple entry dates. Hope they are quick to pay out terminees and not hold on like the previous message.

[GMK]

This is for fully insured welfare benefit plans.

[thepensionmaven]

What about filing for the initial initial plan year?

Can we do an -SF?

[Flyboyjohn]

No, if you're under 100 at BOY you don't file anything for initial year (assuming it's an unfunded or fully insured welfare plan).

Since you didn't file anything for initial year if your welfare plan participant count is 100 or more at beginning of next year you have to file a full 5500 (can't use 80-120 rule)

[GMK]

For example, see item 12 on page 3 here:

https://www.dol.gov/ebsa/pdf/2014-5500-SFinst.pdf