December 3, 2009

Form 5500 Updates

Schedule C Guidance

The DOL’s Employee Benefits Security Administration has provided some new guidance relating to the Schedule C, which is a part of the Form 5500.  The Schedule C, Service Provider Information, is used to report service provider compensation, paid directly or indirectly, by the plan. 

The EBSA guidance addresses several issues, including what constitutes gifts that need not be reported on the Schedule C, such as:

  • Promotional, company-logo type items (coffee cups, calendars, trophies, etc.); or
  • Free business meals, lodging or entertainment expenses provided by individuals who have with a business relationship connected with the plan.

The expanded Schedule C requirements apply for plan years beginning on or after January 1, 2009.

If a health plan is exempt from filing a Form 5500, then it would continue to be exempt from such filing, i.e., it would not be subject to the Schedule C filing requirement. 

Electronic Filing of the Form 5500

As a reminder, also for plan years beginning on or after January 1, 2009, the Form 5500s and appropriate schedule information are to be filed electronically via DOL’s EFAST2 system.  Paper versions of the Form 5500s will no longer be available for plan years beginning on or after January 1, 2009. 


The information contained in this Benefit Beat is not intended to be legal, accounting, or other professional advice, nor are these comments directed to specific situations.

As required by U.S. Treasury rules, we inform you that, unless expressly stated otherwise, any U.S. federal tax advice contained in this Benefit Beat is not intended or written to be used, and cannot be used, by any person for the purpose of avoiding any penalties that may be imposed by the Internal Revenue Service

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