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Welfare Benefit Plan 5500

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We have a client who provides health through a community plan.  Employers pay into it, there is insurance and a trust with assets.  Each participating employer has had to file their own 5500 under their EIN.  The health plan has provided information for Schedules A and I in the past.

I requested the information for 2021 and was told by our client - the health plan is filing the 5500 on behalf of the plan and participating employers no longer need to file a 5500.  I have to think our client will need to file a 5500 marked "Final" as the IRS/DOL will be looking for one since there was a 2020 filing and since we filed an extension 2021.  I am attempting to clarify this with the health plan people but still waiting for a response.  If they don't provide any direction, we will prepare a 5500 for our client to sign and file.  The 5500 program doesn't like a welfare benefit plan with no Sch A or I but I suppose  I can ignore that validation warning.   Better to get one filed and possibly amend later if needed.  We only file a handful of welfare benefit plans and have never had to file a final. 

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I would likely amend the 2020 Form 5500 to reflect a final return, assuming you have confirmed that the employer's 2021 Form 5500 filing requirement has been met with the "community plan."  Without seeing the plan documentation, it's hard to determine what type of plan the community plan is, perhaps a group insurance arrangement or multiple-employer welfare plan (MEWA), etc. 

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