Short Plan Year – Schedule A Question

We will be filing a 5500 for a Welfare benefit plan with plan year of 4/1/22 – 3/31/23.  The plan has more than 100 participants at the beginning of the plan year.

The plan year is changing to 6/1/23 – 7/31/24 so a 5500 will need to be filed for the short plan year 4/1/23 – 5/31/23

We currently report 2 Schedule As.  One is for the plan year and one is for the policy year 1/1/XX – 12/31/XX.  We will request a Schedule A from the insurance provider that uses the plan year.

How do we phrase a request for Schedule A information from the insurance provider that uses a policy year of 1/1 – 12/31  since the short plan year is in the middle of the policy year?  Or do we just use the same Schedule A that was reported on the 4/1/22 – 5/31/23 5500?

Thanks

You should report a Schedule A for each contract year ending with or within the plan year.
 

For the plan year 4/1/22-3/31/23, attach the Schedule A for the policy year 1/1/2022-12/31/22

For the short plan year 4/1/23-5/31/23,  attach the Schedule A for the policy year that ends in the plan year.  The Schedule A for the calendar year policy year, doesn't end within the short plan year. No Schedule A for that particular coverage would be attached to the short plan year filing.

For the new plan year 6/1/23-7/31/24, use the Schedule A for the policy year 1/1/23-12/31/23.

The Schedule A reflects the policy year. I read your message to say that you were going to ask the insurer to produce a Schedule A for the plan year even though that is not the policy year.  If that is the case, I wouldn't do it!