What's a 5500 eligible plan?

If there's any obvious answer to this question on the IRS web site I've yet to find it.

I know that benefit plans that have at least 100 participants at the beginning of the year must have 5500 forms submitted to the IRS. My question is:

If one has several plans under a carrier, what is the plan for the purposes of submitting a 5500? For example, if I have medical insurance under one company in the form of an HMO, and a PPO, do I submit a 5500 when the total is over 100 participants or as each plan reaches 100?

Comments

  • 4 Comments sorted by Votes Date Added
  • Even if one carrier, the HMO and PPO plans are separate and a 5500 return needs to be filed for each, as the numbers wouldn't be combined.

    Go to an IRS.gov site and download the form 5500 with instructions. It will explain the requirements and criteria.
  • Your advice to return to the instructions was a good one. I have a hard copy here, and thought I'd poured through it in previous years and hadn't found the answer. I found an answer this time, which says it depends on the governing document for your plans, which I guess are the Plan Documents. Some folks have PDs for each type of plan, others have "wrapper" documents that combine plans into one document. I guess if you have a "wrapper" document it's the threshold of 100 participants is the total participation in all plans; if it's one plan document per plan its individual totals.


  • Yes, if it's one plan document with multiple coverages, i.e., dental, vision as well as medical, then one 5500 filing. It depends on the Schedule A information as reported to you close to the end of the plan year.
  • Yes you are correct. You have to look at the Wrap document" which is the one actually filing the 5500 since it is the one with more than 100 participants.
    E Wart
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