Summit Comments on DOL's Proposed Revisions to Form 5500

October 4, 2016 China Layne

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On July 21, 2016, the Department of Labor (DOL) Employee Benefits Security Administration (EBSA), Internal Revenue Service (IRS), and Pension Benefits Guarantee Corporation (PBGC) published in the Federal Register a proposed rule outlining revisions to Form 5500. 

WHAT IS FORM 5500?

Form 5500 is an annual report filed by pension, health, and other employee benefits plans required by the Employee Retirement Income Security Act (ERISA) of 1974. The proposed revisions to Form 5500 include an extension of filing requirements to cover a larger population of group health plans and increased specificity for the data collected on service provider fees. The U.S. Government plans to implement revisions to Form 5500 in 2020. 

WHO WILL BE IMPACTED BY CHANGES TO FORM 5500?

As part of the rule making process, EBSA, IRS, and PBGC requested comments from the public on the proposed revisions. Summit is pleased to have provided comments on the implications to future EBSA research and analysis of the proposed revisions to Form 5500. We base our comments on more than six years of experience providing analytical and research support to EBSA on pension and health benefits plans.

WHAT DID SUMMIT SAY ABOUT THE PROPOSED REVISIONS?

We grouped our comments on the proposed revisions to Form 5500 into two categories, revisions related to health plans and revisions related to pension plans.

Health Plans. For health plans, we commented on how several proposed revisions can improve the research and analytic possibilities of the data. This includes extending reporting requirements to plans with fewer than 100 members and introducing a new reporting schedule (Schedule J) to collect information on enrollment and claims data. In addition, we provided several suggestions to help EBSA maximize the analytical benefits of these proposed revisions to the health plans section of Form 5500.

Pension Plans. For pension plans, Summit commented on the implications to research and data analytic exercises from two main aspects of the proposals:

  • Providing a standardized format for plans to report information for the Schedule of Assets
  • Requiring plans to disclose more detailed information about administrative expenses

Stay tuned to the Summit Blog for more information about the proposed revisions to Form 5500.

* Note: DOL recently extended the public comment period until 12/5/2016. Click here to read the comments that have already been posted.

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