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Posted

Suppose you have a business that has been filing 5500 forms separately for Vision, Dental, Medical plans, etc.

Now they switch to a Wrap plan. So only one 5500 filing. Do they have to file a "final" form for the formerly separate plans? That seems crazy, but if they don't, will they get nasties from the DOL?

Geez - look at 2019...

 

Posted

Aargh - now a related question has arisen. Let's say that a client had 3 plans - no wrap document - for 2019. Vision, Dental, and Medical. Medical filed 5500. Vision and dental did NOT, because they had less than 100 participants.

Now effective 1/1/2020, all three plans fall under a wrap document. Seems to me that there is no final filing due for the vision and dental, as they are still existing, just under the wrap plan, and they will be included in the wrap plan filing. Any other opinions?

Posted

I think their database will be looking for the next filing (and the next filing) until the last filing on record denotes either a final filing due to TM or merged into another plan (the wrap).  Betting an auto-letter would eventually be sent out to client for each individually health program  - since each presumably had a different 5500 plan #.  Its an easy check from their perspective for missing 5500s.    

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