Wrap Document for Group Welfare Benefit Plans

[Christine Roberts]

Employer provides several group health benefits, including group medical and a cafeteria plan, and files separate 5500 forms for each plan. Employer wants to consolidate plans under a "wrap document" so as to file a single Form 5500 with applicable schedules (e.g. Sched. F for cafeteria plan).

Provided employer adopts wrap document before the end of the applicable plan year(s), can it file a single 5500 for that year? Or does the existence of separate plans at any time during the applicable plan year require that the employer file separate Form 5500s for each separate benefit?

[Kristina]

Welfare benefits are not my forte, but my question for you is this: What will prevent the DOL from looking for a final 5500 on the disaggregated arrangements that had filings in prior years if you do not file final returns for those arrangements? Therefore, I think you need to file the final return for the arrangements as well as a first filing for the new welfare plan which should have a different 3-digit code than the other arrangements. Hopefully, someone with more welfare experience will validate or invalidate my comments.

[KIP KRAUS]

I agree with kristina. They will be looking for final returns for the individual plans so you should file them.

[Guest Benefits Maven]

Agreed. I have actually done this. If you don't file for the terminations, they'll just be after you to see why you didn't file for those old plans and that's going to get annoying. Once you've done that, however, the one document for the wrap plan going forward will be sufficient.