Logo- 4-9-12
Linda T. Fisher 5500 Consulting, LLC Newsletter
Keeping You Informed!


March 2014


The 2013 Form 5500 season has begun. We are optimistic that many filings, especially unfunded health and welfare plans, can be completed within the next few months. 

 

A few weeks ago my family and I visited our nation's capital - Washington, D.C. I enjoyed seeing a few of my favorite sites: the Lincoln Memorial, Vietnam Veteran Memorial, Arlington Cemetery, the White House (just the outdoor view) and a few Smithsonian museums including the Museum of American History and the Air and Space Museum. The highlight of our trip was a tour of the Capital as we learned about its history including being burned down shortly after it was originally built followed by the strong desire of our leaders to rebuild and show our confidence in this country's future. See below for some of the photos from our trip.

 

We appreciate all of our subscribers and contributors to this newsletter and to your Form 5500 ongoing quality efforts! Our goal continues to keep you informed 5500 experts!

 

If you have been a regular reader of our monthly Form 5500 updates, you have seen that the rules continue to change and new guidance continues to be released. We all strive to stay on top of these changes and guidance which makes our jobs both challenging and exciting. 

 

We continue to provide Form 5500 related government updates in addition to providing helpful articles. We know that you likely have more responsibilities than just Form 5500 preparation, so to keep you in the loop, we are providing 5500 related guidance directly to you! Stay tuned each month to learn about:

  • Solutions to Common Errors;
  • Dept. of Labor and IRS Updates;
  • Specific Schedule Guidance; and 
  • Training Offerings!
Did you miss any prior Newsletter issues? 
Click Here to catch up.
    
Pass this newsletter along to others that will benefit!! 
 
Form 5500 Training for Preparers and Reviewers

  

We Can Assist With Form 5500 Preparer or Reviewer Training!

 

Save time by turning the training task to us! 

 

We know that effective Form 5500 training is hard to find. We can train you and your team on a variety of Form 5500 topics. Whether you have an experienced team that just needs to brush-up on new changes since last year, you have new Form 5500 preparers that need the full training package, or you prepare your company's filings and are not quite sure what it all means. 

 

Is Schedule C still an area of confusion? We can assist with training that will get you on the right track for very low cost.

 

Are you a Form 5500 reviewer that is ultimately responsible for your filings'  accuracy but don't have a good understanding of what it all means? We have an excellent Reviewer Training session that addresses the more important line items and potential red flags.  

 

You and your people deserve to know more!  Retirement and Health and Welfare Plan Compliance is vital!  Click for more about our training offers!
 
Questions? Send them to [email protected] and we can assist!!  

 

In This Issue
2013 Updates, Overview and Practice Tips
Counting Participants Accurately for each Plan Type
Recent Form 5500 Updates
Link to Our Interview with PLANSPONSOR
Did You Catch Our 2013 Updates, Overview and Practice Tips Article?
Practice Tips for our Form 5500 Preparer Community
Did you catch the recent update to our Helpful Hints Article? This is a great resource which provides additional practice tips where the Form 5500 instructions left off. Just click here or the link on our Home Page to request this article. Here is a sampling of the topics addressed:
  • What's New for 2013 Filings?
  • Which Health and Welfare Benefits Are Required to be Reported?
  • Large vs. Small Plan Reporting Concerns
  • Clarifying the 80 to 120 Rule
  • Form 8955-SSA - Addressing Reporting Requirements by Entry Code
  • Six Schedule C Practice Tips  
  • What if the Auditor's Report is not Completed by the Due Date? 
Counting Participants for Each Plan Type is Often Misunderstood
asst-portraits-header.jpg We have previously addressed the importance of accurate participant counts, especially for health and welfare plans since many companies miss this filing requirement, but the DOL continues to discover this type of error. Plan Sponsors are still missing the health and welfare Form 5500 filing requirement when their employee benefit enrollment reaches 100. Conversely, Form 5500 filings for retirement plans are required following the first year of the plan so the filing requirement is usually not missed, however, the way participants are counted is often incorrect.
 
For health and welfare plans, we are to count each employee who actively enrolled in a benefit (e.g. medical insurance) or is covered in a group contract (e.g., basic life insurance). 
 
However, for retirement plans, in addition to employees that have an account balance, we are suppose to count all "Eligibles" which are employees who can participate in the plan. This includes those that may not have yet worked the required hours or months, but they are "earning credited service" to eventually participate. In addition, any separated employees who have an account balance still need to be counted, until their account balance goes to zero.
 
Many plans are under-reporting participants, especially if plan administration firms do not receive employee information for those that are still earning credited service and do not have an account balance. Under- reporting participants could cause plan sponsors to believe they have a small plan which would not require an Independent Auditor's Report, however, if they reported all Eligibles, the count may reach or exceed 100 and an Auditor's Report would be required. This under-reporting may have been happening for several years, and if discovered by the DOL, high penalties will likely be charged. 
 
The DOL continues to look for health and welfare plan filings that report 100 or more participants in the company's retirement plan but have not submitted a health and welfare filing. 
 
If you are aware of any under-reporting or non-reporting cases, we encourage you to communicate this to your clients since it is much better to come forward by submitting delinquent filings through the DOL's DFVC Program where the late fees are much less. 

Recent Form 5500 Updates

Recent updates and announcements regarding Form 5500's:
  • Effective January 1, 2014, IFILE will no longer keep Form 5500's and 5500-SF's that filing authors last updated more than a year ago and have not submitted to the Government.
  • The DOL released a proposal to require a guide or summary that would accompany each covered service providers' 408(b)(2) disclosures to improve participant and employer understanding. This proposal is now open for comment until June 9, 2014.
  • Phyllis Borzi, head of DOL's EBSA, described her agency's new "Prohibited Person's Project" pilot program. This program will track individuals in the service provider community with a history of misconduct so plan sponsors are aware of this. The hope is to eventually roll this program out nationally.
  • Primary reasons a plan is selected to be audited by the DOL include: a participant complaint, a Form 5500 response, or hiring an accounting firm that performs less than 25 employee benefit plan audits per year.
Link to Our Interview With PLANSPONOR!
 
A few weeks ago I had the honor of being interviewed by PLANSPONOR!  I highlighted the importance of hiring a Form 5500 expert to ensure filings are completed accurately, especially since they are often used by the DOL to select plans for audit. We hear too often that filings are prepared "based on last year's form" without the preparer knowing much about ERISA, Form 5500 questioning, potential red flags, and common errors. Click Here for this informative article.


We would love to hear from you! Your comments and questions regarding this newsletter and future topics are important to us!

Click here to provide your feedback!
 
Sincerely,
 

Linda Fisher
Linda T. Fisher 5500 Consulting, LLC
Quick Links
 

 

Like us on Facebook
Join Our Mailing List! 
Our Mission
Linda T. Fisher, owner of Linda T. Fisher 5500 Consulting, LLC  has prepared and managed Form 5500 filings for 18 years and serves as a technical resource for fellow employee benefit plan professionals and plan sponsors that prepare their own filings. 
 
She is fully aware that as employee benefit laws change, it becomes challenging for plan sponsors to keep current with all filing requirements. 
 
Our mission is to educate all those responsible for Form 5500 preparation and review. We do this through our preparation services, offering training programs for both preparers and reviewers, along with 'as needed' coaching.