Agencies propose new, expanded Form 5500 group health plan reporting

Group health plan sponsors would be required to provide significant amounts of information about the plans when filing the annual Form 5500 with the U.S. Department of Labor (DoL), under a recently released proposed rule from the agency, along with a separate proposed rule from the DoL, Treasury/Internal Revenue Service (IRS), and the Pension Benefit Guaranty Corporation (PBGC).

The DoL’s proposal, which affects only ERISA-covered plans, would amend the reporting and disclosure requirements for other welfare benefits and retirement plans, but this Client Action Bulletin (CAB) focuses only on group health plan information, including from sponsors of grandfathered group health plans and from sponsors of certain small plans that to date have been exempt from filing. The DoL anticipates applying the new requirements to plan years starting in 2019 (i.e., filings made in 2020).

For simplicity, this CAB refers to both sets of rules as the DoL’s proposed rule.

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