Q3 Considerations: Health & Welfare Short Plan Year Form 5500 Filing

It is common for a plan sponsor to sometimes change their ERISA plan year. The most common reason is to have their ERISA plan year synchronized with their fiscal year. While preparing for a change in plan years, one challenge is how to handle the Form 5500 filing, if the plan has 100+ participants. Let us look at an example of changing from a July 1-June 30 plan year to a calendar year January 1-December 31 plan year. 

Don's Bagels plan year is 7/1/2023 to 6/30/2024 and they want to change to a 1/1/2025 calendar year ERISA plan year. The short plan year filing would be due 7 months after the end of the short plan year so in our example the filing would be due by 7/31/2025. Don's Bagels would request Schedule A's from the insurance carrier for the short plan year period and file a short plan year Form 5500 from 7/1/2024 to 12/31/2024 making sure to complete Part 1 (B) by checking the short plan year return/report.

Once the short plan year filing is complete, the 5500 would be filed on a calendar year going forward.