Form 5500 Schedule F

[Guest Kelly Furlong]

Scenario: Employer has a Cafeteria plan with group health, dental and the Health care FSA and Dependent Care FSA, all are components of the Cafeteria plan.

Question 1: Under what circumstances, if any, is it necessary to extrapolate out the Healthcare and Dependent Care pre-tax amounts that go on line 6 ("Enter total cost of the fringe benefit plan for the plan year"). In other words, are there any requiremnts that these amounts MUST be reported separately on 2 other 5500, Schedule F's. I say NO.

Question 2: Now assume that the FSA are NOT components of the Cafeteria plan (becuase of poor drafting or some other reason) and the FSA documents have enough language that they each constitute a Cafeteria plan. I say YES, but why would you ever want to do a total of 3 filings when you only need one. Fix the Cafeteria plan document to include both FSA as components.

Please confirm: You need a Schedule A for a Healthcare FSA with more than 100 participants. The cost entered on Schedule A also goes on the Schedule F. I say YES.

THANKS!!!

[Dawn Hafner]

Kelly,

Question 1: Only one Sch F and Form 5500 filing is necessary if all benefits are included under one plan. Just add up all employee pretax premiums for the insurance and the FSA amounts for Sch F.

Question 2: I agree that separate Form 5500s would need to be filed if they were indeed separate cafeteria plans.

Question 3: I disagree. Yes, A Schedule A will be produced for health plans with greater than 100 participants, but this represents premiums paid and fees for the entire health plan. Cafeteria plan filings should only be reporting the employee pre-tax portion of the premiums, not the employer paid portion. That part has nothing to do with the cafeteria plan. The health plan would need to file its own Form 5500 though as over 100 particpants.

[Guest Kelly Furlong]

Thanks a million for responding.

On my third question, it has been my understanding that "the total cost of the fringe benefit plan" included the employer contributions. Please confirm your position that this is not the case.

Also, my question regarding Sch A: does the Healthcare FSA plan (with more than 100 participants) need a separate Sch A?

Just wanted to clarify and confirm my question 3.

Thanks again!!! I posted this question on benefit-l 2 times and nobody responded.

[SLuskin]

Hi, Kelly. Yes, the employer contribution to the plan needs to be included on the Schedule F. No, the 5500 for the FSA with over 100 participants does not need a schedule A -there is no insurance company involved, right? Finally, if a dependent daycare FSA has more than 100 participants, it does not have to file an additional 5500. There is a revenue ruling to this effect, I just can't find it right now.