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VEBA - WRAP - Form 5500 Schedule H


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I have a WRAP document that lists the following plans in Exhibit A as being part of the WRAP:

  • Group Health Plan - A
  • Group Health Plan - B
  • Group Health Plan - C
  • Group Dental Plan
  • Group Basic Life Plan
  • Group Voluntary Life Plan
  • Group AD&D Plan
  • Group LTD Plan 

This is a large plan (10,000+ participants).  The Group Health Plans are funded through a VEBA trust.  This results in the plan needing to file Schedule H and have an IQPA audit the plan.  The other plans (Dental, Life, etc.) do not flow through the VEBA (but they are part of the WRAP).  The employee portion of the premium is withheld and remitted to the applicable insurance companies as would be done in a fully insured plan.

As far back as I can see (10+ years), the Form 5500 Schedule H and the auditor's financial statements have only reported assets and activity related to the VEBA trust.  My understanding is that they audit the plan as a whole, but the financials only cover the Trust.  The question has come up this year as to whether or not that is the correct way to prepare the Schedule H and Financials.  Should the other plans be included too?  I do not believe it would affect the "balance sheet" portion of the Schedule H because the fully-insured benefits would have a net-zero affect, but it would potentially affect the "income statement".

Any help or advice is greatly appreciated. 

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Thanks for your input, ERISAAPPLE.  I think that is the logic that has been used in the past, but I cannot seem to find anything that supports this position.

On the other side, I think the argument would be that the amounts withheld from participant pay checks (contributions) are assets, and then those assets are used to pay insurance premiums.  That is why I am thinking it would not affect the balance sheet of Schedule H (Part I), but it would affect the Income Statement (Part II). 

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I would think if you are meeting 104-44, you would not required to report them.  But I think you may be correct.  It doesn't look like 104-44 applies to a wrap plan if any portion of plan assets are held in trust.  The auditor should be able to answer this question for you.

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