One Form 5500, Two Industries
December 10, 2018
Retirement vs. Health & Welfare when Examining 5500 Data
This article is going to focus on how the disclosure differs for two distinct industries, retirement and welfare. Sponsors fill out a different Form 5500 for these plans and may even file a separate 5500 for multiple types of retirement or welfare plans. A great example is that a Sponsor might have a defined benefit plan and a defined contribution plan. That would result in two different filings with the Department of Labor.
Despite being utilized by both retirement and welfare plans, 5500 data has a lot in common between these two distinct groups. The sponsors who file are primarily private sector employers. That means that government agencies and employers are exempt, whether it’s at the city, county, state, or federal level. There’s a gray area when it comes to non-profits. Those organizations typically file a Form 990 about their expenses and funding, but not a Form 5500. They can elect to file if they feel it is advantageous for them to do so. It’s always worth a shot to search for them!
Many Schedules are filled out by both retirement and welfare plans. The publicly disclosed Schedules are A, MB, SB, C, D, G, H, I, and R. Not every plan files each Schedule though. It depends on the services utilized by the plan, its funding, and how it’s structured. Below we discuss some of the significant differences between the two plans. Most of us are solidly working within one industry, such as retirement, so you can jump to the section that applies to you.
You may have noticed while researching prospects that a behemoth like Acme Explosives disclosed their schedule of assets, an auditor’s report, their annuity carrier and vendors like their record keeper, yet Mom & Pop Shop USA has none of that. Absolutely maddening!
What you’re seeing is the Form 5500-SF, an abbreviated version of the Form 5500. In 2009 the DOL created a short form version of the 5500 to reduce the burden on companies with under 100 participants. With the exception of the Schedule SB, filed by smaller defined benefit plans, sponsors are not required to fill out schedules.
The Schedule A
If a plan has an insurance contract, they need to complete this Schedule. It’s where a carrier and their brokers are disclosed. When disclosing annuity contracts, they fill out Part II for the value of their investments.
The Schedule C
Retirement plans often use this Schedule to list their record keepers, brokers, investment managers, accounts, and so on. Section 2 is where service codes describe what they’ve been compensated for and we can see how much they received. Retirement plans are also more likely to make use of Sections 1 and 3, where we can see if a provider was eligible for indirect compensation and the formula for it.
The Schedule H
Only plans with over 100 participants file this Schedule. It has the same financial disclosure questions as the Form 5500-SF yet many more. You’ve probably heard that these filings also have a Schedule of Assets. As of 2018, the DOL doesn’t have a standard document for this supplementary Schedule. Instead, Sponsors submit attachments which are viewed as PDFs. These are always available in the Retirement Plan Prospector tool once you are looking at the Plan Details pages.
Health & Welfare Plans
Health and welfare plans can cover a wide variety of benefits. As long as they’re ERISA-qualified, it’s likely you can find it. Unlike with retirement plans, the minimum to file is 100 participants. Note, it’s not employees, but the number of individuals in a plan. If a sponsor has under 100 participants in their plan, then they’re exempt from filing a Form 5500.
The Schedule A
Like many of the Schedules, this one can be filled out by both retirement and health and welfare plans. On welfare returns, the Schedule A is often the star. Plans with insurance policies file this schedule and report the carrier, lives covered, premiums, benefits insured, and, if applicable, the brokers who sold the policy.
The Schedule C
When a welfare plan has organizations or individuals who are not insuring benefits, yet providing services to the plan, they’re disclosed here. The most commonly filled out Section is 2, where we see provider service codes and compensation values. Typically this includes third-party administrators, consultants, ASOs, and accountants. Users who work with self-funded plans make more use of this Schedule because it provides clues as to how the plan is managing their benefits.
The Schedule H
Unlike retirement plans, this isn’t as commonly filed. Roughly 10% of the plans in American Directory of Group Insurance have this Schedule. The general rule of thumb, when a plan is unfunded, they’ll file a Schedule H.