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DOL Issues Second Annual ACA Report on Self-insured Plans
Practical Law Legal Update 4-519-1399 (Approx. 3 pages)
DOL Issues Second Annual ACA Report on Self-insured Plans
by PLC Employee Benefits & Executive Compensation
| Published on 25 Apr 2012 • USA (National/Federal) |
The Department of Labor (DOL) released its second annual report, required under the Affordable Care Act (ACA), on self-insured employee health plans and financial information on the employers sponsoring those plans.
The DOL recently issued its second Annual Report to Congress on Self-Insured Group Health Plans, which contains aggregate information on self-insured employee health plans and financial information on the employers sponsoring the plans. The Affordable Care Act (ACA) requires the DOL to prepare and provide this report to Congress annually, based on plans' Form 5500 filings. The first annual report was provided to Congress in March 2011.
The report includes:
- Aggregate statistics describing the self-insured health plans that filed Form 5500s for 2009 plan years, including:
- plan type;
- number of participants;
- number of new plans filing Form 5500;
- benefits offered;
- plan funding and benefit arrangements;
- assets and liabilities of plans that fund benefits through trusts; and
- contributions, investments and expenses of plans that fund benefits through trusts.
- Available financial information on the employers that sponsor these plans, compiled from available public information.
The report also includes a table comparing aggregate statistics for self-insured and combination self-insured/insured plans for 2008 and 2009 plan years. According to the report, more than 50,000 health plans filed Form 5500s for the 2009 plan year, an increase of almost 7% over the 47,000 filings in the 2008 plan year. The 2009 plan year was the first for which all plans were required to file Form 5500 electronically.
In addition, of the 14,800 self-insured heath plans that filed 2009 Form 5500s:
- Just over 2,100 were funded using a trust only.
- Roughly 5,700 were funded exclusively through the plan sponsor's general assets.
- Almost 5,200 were funded using a combination of plan sponsor general assets and insurance.
- The remaining 1,800 filers used a combination of funding arrangements or did not report any funding arrangement.
The DOL cautioned that the report's data is limited and should be interpreted with care because:
- It includes information only for plans that are required to file Form 5500. For example, small self-insured plans (that is, those with fewer than 100 participants) are exempt from the Form 5500 reporting requirement.
- The aggregate financial statistics only reflect amounts held by the self-insured plans in trust, not any amounts paid directly by plan sponsors from their general assets.
- In some cases, health benefits may be reported on the same Form 5500 with other benefits, including disability or life insurance benefits, making it difficult to distinguish how different benefits are funded.
The DOL also released:
The appendices offer more detailed background information and statistics on self-insured plans and the financial status of the employers sponsoring the plans. Among other things, the DOL indicated that it determined plans' funding arrangements using information submitted on Schedules A (Insurance Information), H (Large Plan Financial Information) and I (Small Plan Financial Information).
For analysis of the ACA, see Practice Note: Affordable Care Act (ACA) Overview.