Some brokers do not want to use the Form 5558, the extension for the Form 5500 that prolongs the deadline by an additional two-and-a-half months. They believe that by using the extension, they have failed their clients. Many others and Wrangle view the extension as a worthwhile, free gift from the DOL. Nevertheless, we do understand and respect those who think otherwise.
The best defense to avoid using the extension is to be mindful of what the key tasks are and when to complete them. Those who apply the information below have the best chance to meet the DOL deadline and not need the Form 5558 extension.Ā Ā
Target Deadlines:
| Phase | Task by Broker | Target | January 1 Plan Year Deadlines |
| 1 | Log on to the Dashboard and complete the Plan and Policy information | Within two months of the end of the ERISA Plan Year | End of February |
| 2 | Upload single Carrier Schedules obtained by client & account managersĀ to the Dashboard, or send an email with the Schedules to Data CollectionsĀ | 120 days after the end of the ERISA Plan Year | End of AprilĀ |
| 3 | Once all of the Schedules have been received and 5500 has been prepared by Wrangle, review and provide needed changes and finalize | Within two weeks after Wrangle releases the draft | Early to mid-June |
| 4 | E-FilingĀ | Optimally, no later than two weeks prior to the DOL due date | July 15th at the latest |
Notes:Ā
- Plans under a Trust or MEWA tend to need the extension, due to the additional material required from the client to complete the Form 5500.
- If you use the 5500 for the PCORI fee reporting, you must file by July 31.
5 Key Questions for a Jump-Start:
Determining the answers now, will help you line up what is needed for the Form 5500.
1. Where are the ERISA Plan Documents and SPDs for reference?
– If there are no ERISA Plan Documents and SPDs, the client is out of compliance with the DOL.Ā
– Using carrier contracts will be necessary.
2. Where do you plan to get the participant counts, including those on COBRA?
– At the beginning of the plan year, it is best to use a Census, the end count from last yearās 5500 filing, or carrier billing statement for the last month of the ERISA Plan year.
– At the end of the year count census, carrier billing statement, or the Schedule A that reports employees only.
3. Which benefits are ERISA-reportable and need to be included as part of the ERISA Plan?
– Refer to the ERISA Plan Document and SPD.
– Donāt forget voluntary plans, even those in which the employee pays 100% of the premium.
– If a fully-insured benefit has less than 100 enrolled but is bundled with all of the other benefits, a Schedule A is required.
4. If the client went through a merger or acquisition, what is the status of the 5500s? Do any need final reports?Ā
5. What are the true policy periods for the benefits within the ERISA Plan?
Where to Get Help:
Wrangle is able to help every step of the way. If assistance is needed on loading the Plan Sponsor details in the Dashboard, finding the answers to the five questions above, or needing further reference material, feel free to reach out to Ann McAdam, Technical Consultant at amcadam@wrangle5500.com.