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E-Filing of Form
5500 Reports
For over 34
years, employer sponsors of group health and welfare plans –with
over 100 active participants – have submitted their Form 5500
reports on paper. Starting with the ERISA Plan 2009 filings, the
Department of Labor (DOL) will only accept the reports as
electronic files submitted through their website. This new
e-filing process is called EFAST2 (ERISA Filing Acceptance
System II) and will launch a whole new
approach to filing the Form 5500 report. The Form 5500 report
itself has not changed significantly; only a few minor revisions
have been made. The first reports affected by this change are
those whose ERISA Plan year began on January 1, 2009. In order
to meet the July 31, 2010 filing deadline for January 1 ERISA
Plans, companies should begin preparing for the new e-filing
method now.
E-filing of the
Form 5500 requires two phases:
Phase One: Registering Signature
Any individual who serves as the Plan Administrator and/or Plan
Sponsor signer will need to register their signature to receive
the appropriate credentials from the Department of Labor.
The best practice requires companies to:
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Identify
the individual(s) who are to be signers by the end of
December 2009.
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Select at
least one back-up person to register an e-signature. (To be
a signer on behalf of the Group Health Plan, the person must
meet a
specific list of criteria.)
-
Register
signatures between January and March of 2010 to ensure they
are in place well in advance of the filing deadline.
The process of
registering the signature involves completion of an online form
found on the
DOL’s website (registration is not available until January 2010; however,
proposed screenshots of their website are available now).
The e-signer will need to:
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Provide the
signer’s business contact information (phone, address,
e-mail address, etc.).
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Select
“Filing Signer” under the list of User Types.
-
Create a
password to use to re-enter the DOL’s Form 5500 website (the
online form will automatically generate a User ID).
Once the
registration process is complete the e-signer will receive a PIN number
that will serve as the e-signature at the time of filing. Those
who receive the PIN are encouraged to print and carefully store
the PIN information. The DOL has set up a Help Line to assist
retrieving lost PINs at 1-866-GO-EFAST (463-3278), however it
will delay the filing process.
Phase Two: E-Filing Form 5500 Report to
DOL
Administrators and brokers often utilize a reputable third party
software vendor authorized by the DOL to generate the Form 5500
reports for their clients (most disregard the DOL’s online
system called IFILE due to system limitations). Prior to
finalizing the report to e-file, many of these systems run a
validation process to help detect any errors that EFAST2 may
discover.
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Once finalized, the Form 5500 will
be submitted to EFAST2, which will then notify the
e-signer if the file was accepted or not accepted within 20
minutes. If the file was not accepted, the errors detected will
be outlined. Some types of errors detected will require the
report to be resubmitted as is. Other errors will require the
report to be modified before being resubmitted as an amended
filing (click
here to see the possible error messages).
Frequently Asked
Questions:
- Do you need separate
registration for the Employer/Plan Sponsor and for the Plan
Administrator if the two roles are completed by the same
person?
No, you can register for both purposes.
- Can the preparer of the
Form 5500 obtain the PIN from the e-signer and submit it on
their behalf?
No. The DOL strictly requires that the PIN not be shared.
The e-signature attests that the e-signer has examined the
report and is responsible for the report to be complete and
e-filed.
- Can a signer’s contact
information be updated?
Yes. On the EFAST2 website you can click “Profile” and
update the contact information
- Can attachments be
submitted?
Yes, Adobe Acrobat files (PDFs) may be attached.
- Is the e-signer the only
person who has access to the status of an e-filing?
No. Anyone can check the status by calling the EFAST2
Help Line at 1-866-463-3278 and using the automated voice
system.
Additionally, all filings including the Schedule As and
attachments will be available for view to the general public
through the
DOL
website.
- Has the process to apply
for an extension been changed?
Partially. Form 5558 will still be completed on paper and
mailed to the IRS. Previously, the Form 5558 was to be
included with the Form 5500 upon filing. Now when the Form
5500 report is e-filed, the Form 5558 is not included.
- Are amended filings also
submitted through EFAST2?
Yes. In the event of an amended filing the entire report
should be resubmitted electronically.
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