The DOL has released the 2017 Form 5500s. At first glance, it appears to be a very close replica to the 2016 Form 5500. However, there is a significant step that the DOL took with 2017’s Form 5500 that has far greater implications.
If your Plan Name changed from 2016 to 2017, this needs to be called out on the second page of the 5500.
For an example:
- 2016 was noted as ABC Company Health and Welfare Plan
- 2017’s is to be noted as ABC Company Health Plan.
Why does this make such a great impression on Wrangle? For one reason: the 5500s have been around since reporting began back in the 1970s and yet this is the first time the Plan Name change is to be noted (The DOL has requested for changes in the Plan Sponsor name or its EIN/ Tax ID to be pointed out).
Wrangle surmises that the DOL is starting to focus on the Plan Name changes as a segue way to also show more emphasis to be given to Plan Documents and Summary Plan Documents (SPDs). After all, the 5500 is a reflection of the Plan Documents/SPDs; however many Plan Sponsors don’t know of Plan Documents, the SPDs, their ERISA compliance requirements or the penalty fees for noncompliance.
In Wrangle’s opinion, the DOL has not really promoted Plan Documents in many aspects, except they do ask for the documents immediately when the audit is to be conducted. Wrangle can picture many blank faces of those in HR when this document is requested.
Still why the switch? Wrangle wonders if this step on the 2017 Form 5500 and asking about the Plan Name change is an indication that more details on Plan Documents and SPDs are to come to the Form 5500. Will those proposed 2019 Form 5500 changes really come to light down the road?
The proposed changes to the 2019 Form 5500s (which have remained under the radar now for many months) included a new Schedule J. And on the Schedule J the Plan Administrator of the Plan is to vouch if the SPD has been distributed to the Plan Participants. If the Plan Sponsor has not, then they were to check off no. As a result though, they would be out of compliance and the DOL could choose to apply the penalty.
We are nervous if this is the development since we are very well aware of so many who are not in compliance on Plan Documents and SPDs. As a result we are closely monitoring this development with the 5500s and making greater efforts to educate our brokers and direct clients on the need for Plan Documents/SPDS and their ties to the Form 5500.
CRITICAL INFORMATION IMPACTING YOUR FORM 5500 Reports from Wrangle
Wrangle is moving its internal database structure to a 100% web-based shared database platform called: Wrangle Dashboard
What Does This Mean to You? You will have direct access to this web-based program to:
- Remove the need for PDF worksheets and go to an eWorksheet
- Provide the ability to see what Schedule As are needed in real-time
- Access to status on your Form 5500 reports 24/7
- Overall – You’ll have a web-based solution for your 5500 needs!!
Some key features to share now are:
- The database will auto-populate much of the worksheet after just the Plan Sponsor’s Name, EIN and Plan Year are added since the Dashboard is connected to the DOL’s EFAST2 system and our prior database.
- As a monumental step, the e-Filing process has a seamless and efficient flow since we have developed our own Form 5500 software to eFile with the DOL’s site. The DOL approved our software and we are ready to go!
- No more email signed documents. We have DocuSign in place for eSignatures.
This is a Whole New ERA for Wrangle!!! Join Us.