Employers that only offer Health Savings Accounts (HSAs) or Qualified Small Employer HRAs (QSEHRAs) do not need to file Form 5500—because these arrangements are not considered ERISA-covered welfare plans.
HSAs:
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HSAs are individual-owned accounts, not group health plans.
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As long as the employer limits its role to contributions and payroll deductions, the HSA is not subject to ERISA.
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HSAs offered alongside a high-deductible health plan (HDHP) may be mentioned in SPD materials, but the HSA itself doesn’t require a 5500.
QSEHRAs:
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QSEHRAs are exempt from ERISA by law, so no Form 5500 is required.
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Employers must meet eligibility rules and provide required QSEHRA notices, but no SPD or 5500 filing applies.
However, if an HSA or QSEHRA is offered alongside other ERISA-covered benefits, those other plans may still require a 5500 filing if the employer meets the participant threshold.