Most CFOs think about Form 5500 in July. By then, you're already behind.
For calendar year plans, the U.S. Department of Labor sets the deadline at July 31, the last day of the seventh calendar month after your plan year ends. That's not much runway if you're starting from scratch in late June.
Self-funded plans don't get the easy exemptions. According to Benefits Law Advisor at Fox Rothschild, Technical Release 92-01 exemptions from reporting requirements don't apply to self-funded plans. Every self-funded health plan files. No exceptions.
Know What You're Filing Before You Start Gathering
The schedules you need depend on your participant count. Ameriflex's Employer's Guide to Form 5500 puts it clearly: 100 or more participants at the start of the plan year, or any plan funded through a trust, triggers the full filing requirement.
Here's what that means in practice.
- Under 100 participants: Form 5500 plus Schedule I.
- 100 or more participants: Form 5500 plus Schedule H and an independent qualified public accountant (IQPA) audit report.
- All self-funded plans: Schedule C for service provider compensation, Schedule A if any insured benefits are wrapped in.
Get your participant count confirmed now. Not estimated. Confirmed. That number drives everything else.
Schedule H: What Your TPA Needs to Pull
Schedule H is the financial statement for large plans. It covers assets, liabilities, income, and expenses for the plan year.
According to Fidelity's Form 5500 resource, total plan assets include rollovers, transfers from other plans, and unrealized gains and losses. Either cash or accrual basis works, but you have to stay consistent year over year. Pull that information from your TPA and stop-loss carrier now, not in July.
If you're a large plan, your IQPA will need documents before the audit even starts. Fox Rothschild's Form 5500 audit guide lists the typical request: the plan document with all amendments, the current Summary Plan Description, custodial statements, and a draft Form 5500. If you're missing any of those, now is the time to find out.
Schedule C: Don't Guess at Compensation Disclosures
Schedule C trips up a lot of employers. You're required to report compensation paid to service providers, but only amounts over $5,000 per year. The DOL's Analysis of Form 5500 Filing Patterns confirms that so-called "eligible indirect compensation" doesn't have to be reported on Schedule C at all.
You still need to know what your TPA, stop-loss broker, and any other service providers received. Ask them directly. Get it in writing. "I'm not sure" is not an answer you want on a federal filing.
| Schedule | Who Files | Key Data Needed |
|---|---|---|
| Schedule H | 100+ participants | Assets, liabilities, income |
| Schedule I | Under 100 participants | Summary financials |
| Schedule C | Large plans | Compensation >$5,000 |
| Schedule A | Insured benefits | Carrier premium data |
| IQPA Report | 100+ participants | Audited financials |
Your 60-Day Action List
Move on these now. Don't wait for your TPA to send a reminder.
- Confirm participant count as of January 1, 2026.
- Identify which schedules apply to your plan.
- Contact your TPA and request all financial data for Schedule H or I.
- Ask every service provider for a written compensation disclosure above the $5,000 threshold.
- Pull your plan document, SPD, and all amendments. Send them to your IQPA if a large-plan audit is required.
- Verify Schedule A data with any fully-insured carriers for wraparound or ancillary coverage.
- Confirm your plan's accounting basis (cash vs. accrual) is consistent with prior years.
- Set an internal deadline of July 1 for a complete draft. That gives you 30 days of buffer.
The DOL's filing pattern research found that financially stressed plans, those in the bottom 25% by income-to-asset ratio, had a 12.7% skip-filer rate. Missing a filing isn't a paperwork problem. It's a fiduciary one.
Don't Let July 31 Sneak Up on You
An extension is available. It's not automatic, and it doesn't fix disorganization. It just delays the consequence.
The CFOs who file clean, on time, every year are the ones who started in May. You've got the list. What's your first call?