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Pharmacy Benefit Manager Fees Must Be Reported on Schedule C
Deloitte via BenefitsLink.com Link to more items from this source
[Guidance Overview]
Feb. 16, 2010

"Not all welfare plans are required to annually report on Form 5500 or Schedule C. A plan that covers less than 100 participants at the beginning of the plan year -- and which is unfunded, fully insured, or a combination of both -- is exempt from the annual reporting requirement. See [DOL] Regulation section 2520.104-20 and 2009 Instructions to Form 5500, page 4. Where such a welfare plan has 100 or more participants at the beginning of the plan year, it is subject to the annual reporting requirement but is not required to file Schedule C."

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