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Update on Form 5500 Filing Requirements for Health & Welfare Plans

Update on Form 5500 Filing Requirements for Health & Welfare Plans
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by Christopher Macali on 10 April, 2017 with Add new comment

As we approach the July 31 filing deadline for calendar year plans, it is helpful to look at the Form 5500 filing requirement for health and welfare plans. As a refresher, Form 5500 requirements are part of ERISA’s reporting and disclosure rules. These rules apply to all group-sponsored health and welfare plans unless an exemption applies. Specifically, plans with 100 or more participants on the first day of the plan year must file an annual Form 5500 with the federal Department of Labor. The filing is due on the last day of the 7th month after the plan year ends. The DOL requires electronic filing through the EFAST2 system.

You may have read in the past year about a proposed DOL regulation to expand the Form 5500 requirement to plans of all sizes beginning with the 2019 plan year. (In order words, the exemption for plans with less than 100 participants would be removed, such that all plans were required to file.) This proposed regulation was issued in mid-2016 under the Obama administration. It is unclear whether the proposed regulation will proceed under the current administration, but our feeling is that the regulation is likely to be changed or otherwise not implemented. This will be a topic to watch between now and the proposed 2019 effective date.

Education & Training Webinar on April 18:

On Tuesday, April 18, we are hosting a training webinar on this topic for employers and plan advisors. This session is designed to provide an overview for large employers and address common scenarios and mistakes with Form 5500 compliance.

You may register for the webinar here. After the session, a copy of the slides and recording will be available upon request.

ProBenefits 5500 Preparation Service:

We have an advanced 5500 filing service to assist employers with this annual requirement. A summary of our 5500 preparation service is available on our website. We are currently serving hundreds of employers in various regions of the country, and we are available to assist your organization.

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Christopher Macali

Christopher Macali

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