Many HR professionals associate Form 5500 with retirement plans, but it also applies to certain health and welfare plans. Accurate filings help document plan activity, support fiduciary oversight and help organizations manage their reporting obligations.
What is Form 5500?
Form 5500 is a federal reporting requirement that’s used by the Department of Labor (DOL), the Internal Revenue Service (IRS) and the Pension Benefit Guaranty Corporation to monitor employee benefit plans. It requires plan sponsors and administrators to disclose information about a plan’s operations, funding and compliance.
For health and welfare plans, Form 5500 generally applies to ERISA-covered plans based on how they are funded and their size.
Common health and welfare plans that may require filing Form 5500 include:
- Medical and prescription drug coverage
- Dental and vision benefits
- Group term life insurance
- Short-term and long-term disability benefits
- Certain employee assistance programs (EAPs)
- Some Flexible Spending Accounts (FSAs) and Health Reimbursement Arrangements (HRAs)
When counting plan participants, employers should typically include enrolled employees and COBRA beneficiaries receiving benefits, but not dependents or spouses. Counting rules can vary, so HR teams should review current DOL guidance for more specific instructions.
Who Must File: Form 5500 Filing Triggers and Exemptions
The plan administrator named in the plan document is responsible for filing a separate Form 5500 for each ERISA-covered plan that meets the filing thresholds, unless benefits are combined under a wrap plan. In many organizations, the plan sponsor or an administrative committee serves as the plan administrator.
General welfare plan filing triggers include:
- Unfunded or fully insured welfare plans with 100 or more participants on the first day of the plan year (see participant counting methodology above)
- Welfare plans of any size that are funded through a trust, including self-funded plans that hold plan assets in a trust
Common exemptions for health and welfare plans include:
- Small, unfunded or fully insured welfare plans with fewer than 100 participants
- Governmental plans sponsored by the federal government, state or local government entities
- Church plans that are exempt from ERISA
- Certain voluntary plans that meet DOL safe harbor criteria, where employer involvement is limited
Types of Form 5500 Filings
The Form 5500 series includes several versions of the form that are designed for different plan types and sizes. Understanding which form applies to your welfare plans can help streamline the filing process.
- Form 5500 is the standard annual return used by large plans with 100 or more participants or plans with more complex structures. Most health and welfare plans that meet filing thresholds use this version of the form.
- Form 5500-SF (Short Form) offers simplified reporting for eligible small plans that meet specific DOL criteria. This form reduces administrative burden while satisfying annual reporting requirements for qualifying plans.
For welfare plans, most filings are made using Form 5500 or Form 5500-SF. Both forms must be filed electronically through the DOL’s EFAST2 filing system; there is no paper filing option for these forms.
What information goes in a health and welfare Form 5500?
Form 5500 for welfare plans captures several categories of information that help regulators to assess plan operations and compliance status.
Plan and Sponsor Information
- Plan sponsor’s Employer Identification Number (EIN)
- Plan name and number
- Types of welfare benefits offered (e.g., medical, dental, life, disability)
- Plan year dates (for a calendar-year plan, January 1 through December 31)
- Number of participants at the beginning and end of the plan year
- Information about beneficiaries receiving benefits under certain arrangements, such as COBRA
Funding and Benefit Arrangement Details
- Whether benefits are unfunded, fully insured, provided through an HMO or funded through a trust
- Insurance contracts and carrier information
- Information about plan assets for trust-funded arrangements
Schedules for Health and Welfare Plans
Schedule A reports information about insured benefits and HMOs, including carrier details, premiums and commissions. This data is typically provided by the plan’s carrier but should be reviewed by the plan sponsor for accuracy.
Schedule C applies in limited cases for service provider compensation that falls above certain thresholds (typically $5,000).
While the most commonly used schedules for health and welfare plans are Schedules A and C, there are additional ones that may apply:
- Schedule D applies to plans or Direct Filing Entities (DFEs) that invested or participated in Common/Collective Trusts (CCTs), Pooled Separate Accounts (PSAs), Master Trust Investment Accounts (MTIAs) or 103-12 Investment Entities (103-12 IEs) at any point during the plan year.
- Schedule G is required for large plans (100 or more participants), MTIAs, 103-12 IEs and GIAs that have loans, fixed income obligations or leases that are in default or classified as uncollectible or that have nonexempt transactions for benefit plans.
- Schedule H reports financial information for large plans and DFEs and is typically required for them.
- Schedule I reports financial information for small benefit plans (under 100 participants) and is required for small plans that are not eligible to file Form 5500-SF.
- Schedule MB, Schedule SB and Schedule R apply to retirement plans and pension arrangements.
Deadlines, Extensions and DFVCP
Form 5500 filings follow strict deadlines that HR teams must track. The annual report is generally due by the last day of the seventh month after the plan year ends, which is July 31 for calendar-year plans. Plan administrators may be able to request a one-time extension by filing Form 5558 before the original due date.
Late or missed filings can lead to significant penalties from both the IRS and the Department of Labor. In 2025, the penalty for failing to file Form 5500 was $2,739 per day.
The Delinquent Filer Voluntary Compliance Program (DFVCP) allows plan administrators to correct late filings and reduce potential penalties if action is taken before a DOL notice is issued. However, all required forms must be submitted for each missed year, and penalty structures may change, so reviewing current DOL guidance is important.
Practical Filing Steps for HR and Benefits Teams
A systematic approach to Form 5500 filing helps HR teams improve accuracy and consistency. Consider these steps when preparing welfare plan filings:
- Confirm plan structure and ERISA coverage. Review plan documents to identify which health and welfare plans are ERISA-covered and whether benefits are combined under a wrap plan or need to be filed separately.
- Determine filing requirements. Apply the 100-participant threshold using counts from the first day of the plan year and identify trust-funded plans subject to additional filing requirements.
- Select the correct form. Determine whether Form 5500 or Form 5500-SF applies based on plan size and complexity.
- Gather carrier information. Request Schedule A data from each insurance carrier and allow time for follow-up.
- Collect internal data. Compile participant counts using payroll and enrollment records, including COBRA participants.
- Confirm EFAST2 access. Verify filing access and electronic signature credentials, as electronic submission is required for Form 5500.
- Complete a final review. Check for common issues, such as inconsistent plan details, incorrect counts or missing attachments, before filing.
- Keep records and receipts. Retain EFAST2 submission confirmations, signed copies of Form 5500, carrier-provided Schedule A information and any supporting documentation.
- Distribute summaries. For many plans, administrators must provide a summary annual report to participants and beneficiaries within the required timeframe.
Wrap Plans, Multiple Policies and How Many Form 5500s You Need
Employers often offer multiple welfare benefits, such as life, medical and vision, through different insurance carriers. Without consolidation, each benefit plan may require its own Form 5500 filing if it meets applicable thresholds.
A wrap plan combines these benefits under a single ERISA plan document, allowing the employer to file one Form 5500 with multiple Schedule A attachments.
HR teams should review plan documents and carrier arrangements to determine how benefits are structured. A wrap plan may simplify reporting, but it should be evaluated with guidance from the organization’s legal counsel and employee benefit advisors.
Common Health and Welfare Form 5500 Pitfalls
Several common errors can affect welfare plan filings, but awareness of these issues can help HR teams to reduce risk and improve accuracy. Some common mistakes include:
- Treating voluntary benefits as exempt without confirming whether plans meet the DOL safe harbor criteria
- Miscounting participants (for example, excluding COBRA beneficiaries or including dependents)
- Using inconsistent plan names or numbers across filings and plan documents
- Missing or incomplete Schedule A data
- Incorrect responses to compliance questions, including those related to prohibited transactions
Midyear plan changes, such as switching insurance carriers, can also complicate reporting and may require additional coordination. Before filing, compare drafts to prior filings and plan documents.
Simplify Compliance with a Benefits Broker
Many employers work with brokers, consultants or ERISA counsel to support Form 5500 preparation and review. An experienced benefits advisor can help identify which plans require filing, coordinate data across carriers and review drafts for consistency with plan documents and compliance requirements.
Higginbotham works with HR teams to evaluate plan structures, implement cost-saving strategies and support long-term compliance. Connect with an employee benefits consultant to discover how Higginbotham can help your organization streamline benefits.
