5500 Filing for ICHRA Plans

5500 Form filing for Employers

Form 5500 Filing: Form 5500 is an annual report filed with the Department of Labor (DOL) that provides information about your employee benefit plan. This filing is essential as it offers transparency and oversight, ensuring that the plan is operating in compliance with ERISA (Employee Retirement Income Security Act) regulations. Additional information can be found here, provided by the IRS.

Who Must File Form 5500: If your health plan covers 100 or more participants at the beginning of the plan year, it is generally subject to Form 5500 filing. However, certain small plans may be exempt from filing based on participant count.

Form 5500 Filing Deadline: Form 5500 must be filed by the last day of the seventh month following the end of the plan year. For calendar-year plans, this deadline is July 31st of the following year. However, a 2.5-month extension is available if requested before the original deadline by filing form 5558.

ICHRA Plan Number: The Plan ID is a 3-digit number that designates one plan from another for the IRS and DOL. Which number goes to what plan is up to the employer in most cases.

In the instructions for Form 5500, the IRS states that Plan ID numbers are to begin with 501 for a company’s first health & and welfare plan. The second plan is to be numbered 502, a third numbered 503, and so forth. This numbering system continues for as many plans as a company has over its lifetime with only two numbers disallowed: 888 and 999.

Here is an example of how an employer might number the different plans a company provides for employees:

Employer Benefit Plan Plan ID No.
Section 125 Cafeteria Plan 501
Health Reimbursement Arrangement 502
ERISA Wrap SPD 503

Every company offering a group health plan should have at least two Plan ID numbers active: 501 for the main group health plan (Section 125 or HRA), and 502 for the required ERISA Wrap SPD.