Big Changes Ahead for the Form 5500
Changes to the forms and regulations that govern annual employee benefit plan reporting on the Form 5500 were recently proposed by the DOL and IRS. The changes significantly increase the annual reporting obligations. The proposed regulations would drastically limit the exception for small health and welfare from reporting. All employer-sponsored group health plans subject to ERISA would need to file a Form 5500, regardless of a plan’s size. Additionally, the proposed regulations limit the eligibility for plans to file the 5500-SF and require a new Schedule J for group health plans. Schedule J would require group health plans to report detailed information about plan operations and compliance with the Affordable Care Act; for example, information regarding the type of benefits offered under the plan and detailed claims payment data. The comment period for the new regulations ends on October 4, 2016 and the new reporting requirements, if adopted, would begin for plan years beginning on and after January 1, 2019.