Nonprofit Resources


Do You Need to File Form 5500 for Your Health and Welfare Plans?

Many nonprofits are aware of the IRS Form 5500 filing requirement for retirement plans. However, many aren’t aware that they may need to file Form 5500 for their health and welfare plans, too. This includes medical, dental, vision, and short- and long-term disability plans.

The due date is the same as for retirement plans, but the requirements are not.

The table below breaks out the requirements to file. These are based on participant count and how the plan is funded:

  • Self-funded – claims are paid directly from the employer’s general assets
  • Fully-insured – the employer pays premiums to an insurance company, and the insurance company pays the claims

To calculate the number of participants for health and welfare plans, count the number of enrolled participants, plus those in COBRA and those receiving post-retirement benefits. Do not include dependents in the count.

Form 5550 Filing and Audit Requirements for Health and Welfare Plans

Participant count at beginning of yearSelf-funded or fully insured, or combination self-funded/fully insuredNot completely self-funded or fully-insuredChurch Plan
<100 participantsNo Form 5500Form 5500, no auditExempt
>100 participantsForm 5500, no auditForm 5500, audit requiredExcept

A welfare benefit plan with employee contributions that is associated with a cafeteria plan under Code section 125 may be treated as an unfunded welfare plan for annual reporting purposes. See the Form 5500 instructions for details.

If you have any questions, please contact your engagement team or email us at [email protected].

Emily Toler

Emily serves as a partner in the Indianapolis office and as the firm’s Employee Benefit Plan Services Director. Emily has 20 years of experience providing audit and tax services for employee benefit plans, with a primary focus on 403(b) plans. She currently oversees approximately 70 benefit plan audits and related filings. Emily also is a member of the AICPA Employee Benefit Plans Audit Quality Center Executive Committee.


  • Peggy Anne Haflinger says:

    Just curious. If the plan has greater than 100 participants and the participants contribute to the plan in addition to the company contributions, is that when the audit is required?

    • Emily Toler Emily Toler says:

      Peggy Anne,

      The audit trigger for health and welfare plans with 100 or more participants is related to the type of health and welfare plan it is, not who is contributing.

      If the plan is unfunded (also known as self-funded), fully-insured, or a combination of both, the plan must file a Form 5500 but is exempt from an audit. Generally, plans that maintain a trust to pay claims and/or premiums are required to include audits with their Form 5500s.

Leave a Comment