Schedule As are widely used and generally well understood; however, their distinctions from Schedule Cs are less commonly recognized. The following table clarifies the key differences between the two schedules, and additional explanatory information on Schedule C reporting requirements is also provided.
Schedule A vs Schedule C
| Schedule A | Schedule C | |
| Funding | For fully insured (premium-based) insurance policies | Only to report fees paid out of trust fund assets to entities for services provided to the Plan |
| Main Attributes | Includes the total premiums within policy period plus participants (covered persons, which includes employee + dependents) | Includes the fees paid out of the trust’s plan assets to service providers for legal, marketing, etc. |
| How are commissions relayed? | Commissions, bonuses, or other sources of revenue from the Carrier to Broker are to be noted | Broker’s commissions are not reportable on the Schedule C. However, if the broker’s fees were paid out of trust fund assets, then those would be reported on the Schedule C. |
| Who is listed for services? | DOL requires the name & address of Broker(s) – if applicable | DOL requires Service Provider(s) and their EIN number |
Main Takeaway on a Schedule C
A Schedule C is to be included if there is a large group trust. If a group does not have a trust but has a self-insured benefit and the carrier provides a Schedule C, the Schedule C is only included again if there is a large trust.
Per page 26 on the DOL’s Form 5500 Instructions:
Health and welfare (H&W) plans that meet the conditions of the limited exemption at 2520.104-44 or Technical Release 92-01 are not required to complete and file a Schedule C.”
[In other words: H&W plans that funds through general assets and not Plan Assets are exempt. Also plans that are exempt from filing the Schedule H (covers the financial reporting) and an accountant’s opinion (IQPA audit), because they rely on the trust non-enforcement policy of Technical Release 92-01*, are exempt from filing Schedule C.
What if the Schedule C was incorrectly included? Do you amend the Form 5500?
The decision is up to the Plan Sponsor. Including Schedule C overreports if the plan is not funded through a trust. Going forward, it would not be included.
Feel free to reach out to Ann McAdam at info@wrangle5500.com with any questions.