Short answer: Form 5500 is required for ERISA-covered welfare benefit plans that meet the size or funding thresholds: generally medical, dental, vision, health FSA, group life, and disability plans with 100+ participants or that are funded. Individual HSAs and QSEHRAs generally do not require a filing.
Form 5500 is required for most ERISA-covered welfare benefit plans that meet certain size or funding thresholds.
Common plans that may require filing:
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Group health insurance plans (medical, dental, vision)
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Health FSAs (unless excepted under the cafeteria plan exemption)
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Group term life insurance
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Short- and long-term disability plans
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Accident or hospital indemnity plans
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Employee assistance programs (EAPs) that provide medical care
Plans that typically do not require filing:
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HSAs, if offered without an ERISA-covered group health plan
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QSEHRAs (Qualified Small Employer HRAs)
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Voluntary plans that meet strict ERISA exemption criteria
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Plans with fewer than 100 participants that are unfunded or fully insured
Employers must evaluate each benefit offered to determine if it’s ERISA-covered and whether it should be included in a Form 5500 filing, especially when using a Wrap document that consolidates multiple plans.