No Schedule A or C Required for Most Self-Funded Health Plans

In general, there is no Schedule A requirement for a self-funded plan. Schedule A is used to report on insurance information. If an entity does not provide insurance, there is no Schedule A reporting requirement with respect to the group contract.

Schedule A reporting of a stop-loss policy on Form 5500 is required when the stop-loss policy is an asset of the plan (e.g. funded via a trust).

Likewise, any self-insured plan that qualifies under Technical Release 92-01 is not required to file a Schedule C. That includes self-insured plans that are not funded through a trust and which take EE contributions pre-tax through a cafeteria plan. It is more common for self-insured plans to pay claims through the company’s general assets and take employee contributions pre-tax therefore they rarely have a Schedule C requirement.

The purpose of a Schedule C is to report fees of $5,000 or more paid out of trust or plan assets to a vendor who provided services to the ERISA Plan. Its purpose is not to report self-funded fees or commissions paid (unless paid out of the trust).

A self-funded plan is though represented on the 5500 by virtue of a benefit code (e.g. 4A for medical on line 8B) and by checking general assets in 9a/b.

Why does it matter?

The DOL has indicated that including a Schedule C can be a red flag, as they then look for the other trust reporting elements, i.e. the Schedule H and audit. 

If you have questions about the above, or need help with another employee benefits administration question, please contact us! We would love to hear from you!

The Compliance Rundown is not a law firm and cannot dispense legal advice. Anything in this post or on this website is not and should not be construed as legal advice. If you need legal advice, please contact your legal counsel.

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