Are You Prepared for the New Form 5500 Electronic Filing Requirements?
It can be difficult to keep track of all of the recent legislative activity regarding health and welfare benefit plans these days. In 2009, our industry has already seen a new COBRA subsidy, expansion of the Children’s Health Insurance Plan (CHIP), the Health Information Technology for Economic and Clinical Health Act (HITECH), and numerous versions of healthcare reform proposals. However, there is a new twist on an old requirement that has been lightly discussed yet will have a significant impact on the way employers report information on their benefit plans.
Yes, the Department of Labor has now mandated electronic filing and disclosure of all Form 5500 annual reports by announcing that paper versions will no longer be accepted for filings for the 2009 plan year. Thus, beginning January 1, 2010, any company that sponsors a retirement or welfare benefit plan and is required by the Department of Labor to file a Form 5500 must do so electronically instead of by mail. (Note: Typically, welfare benefit plans with 100 participants or more are required to file Form 5500s.)
According to guidance from the Employee Benefits Security Administration (EBSA), 5500 files must be submitted via an electronic system known as the ERISA Filing Acceptance System II, or EFAST2. Available on January 1, 2010, this system allows users to prepare and submit 5500 files either through EBSA’s web-based filing system (known as IFILE) or by special software from an EFAST2-approved vendor.
The change is effective for 5500 submissions for all plan years beginning in 2009, including amended and delinquent filings. Employers filing a 2009 short plan year Form 5500 that would be due before January 1, 2010, will be given an automatic extension to electronically file within 90 days after the new IFILE system is available on the DOL website.
With these changes now in effect, employers who prepare their own Forms 5500 in-house will need to determine as soon as possible which method they will use to file (IFILE at the DOL website or other approved third party vendor software). In addition, because the system is so new, employers should anticipate a longer preparation time for their 5500 filings.
If you use a consultant, broker or other third-party vendor to file your Form 5500, you may want to verify that the entity is fully prepared for filing under these new electronic standards. Hill, Chesson & Woody has already made the necessary preparations and fulfilled the needed requirements to be able to file 5500s electronically for our clients.
For complete information about the EFAST2 system, including a list of frequently asked questions and related resources, visit the DOL’s EFAST page at www.efast.dol.gov. Additional information can be found by visiting the following links:
Mandatory Electronic Filing of 5500s to Begin in 2010
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Don't forget to visit the HCW Wellness Corner at www.hcwbenefits.com!
By visiting the HCW Wellness Corner, employers can order various resources to help them initiate, strengthen and/or enhance their wellness initiatives. Best of all, these resources can be sent directly to the employer completely FREE OF CHARGE!
So visit the HCW Wellness Corner today at www.hcwbenefits.com, and let us help you get your company on the road to wellness!
Important Notice: Hill, Chesson & Woody does not engage in the practice of law, accounting, or medicine. Therefore, the contents of this communication should not be regarded as a substitute for legal, tax, or medical advice.
October 9, 2009
Hill, Chesson & Woody strives to keep our clients' group decision makers abreast of trends influencing the employee benefits market. Look for Eyes on Benefits to bring you news and information affecting you and your employees.
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www.hcwbenefits.com