Filing guide
Form 5500 search: finding your filing
Search the U.S. Department of Labor EBSA EFAST2 Form 5500 Search at efast.dol.gov/5500Search, and use the DOL FOIA Form 5500 datasets when you want the bulk files. An employer health plan generally files when it had 100 or more participants at the beginning of the plan year, for an unfunded or insured ERISA welfare plan under 29 CFR 2520.104-20, unless plan assets are held in a trust or another exception applies. The filing threshold is not the state large-group line and not the IRS 50-employee test.
For CFOs, controllers, and owners.
Search the EIN, not the name on the door
Open EFAST2 Form 5500 Search. Type the Employer Identification Number from the company’s tax return or W-2. Name search is the slow path: the sponsor line is the legal name tied to that EIN. A DBA, a trade name, or a division often returns nothing.
If the EIN you have is the operating company’s and the filing is missing, check the parent or the holding company. Welfare plans are often sponsored one level up. The bulk files, if you need several years or a peer set, are the DOL FOIA Form 5500 datasets.
Plan number. Welfare plans are numbered 501 and up. Retirement plans are numbered 001 and up. A 401(k) at 001 is not the health plan. Open 501, 502, and 503 before you conclude the health plan did not file.
How old the newest file is. Form 5500 is due the last day of the seventh month after the plan year ends. Form 5558 extends that by two and a half months, to nine and a half months after year end. A calendar-year plan’s filing for last year may not be public until mid-year, or later with the extension. Expect the newest public filing to be one to two plan years back. That lag is normal. It does not mean the plan stopped filing.
A plan with fewer than 100 participants at the start of the year is generally exempt if it is unfunded, insured, or a combination, and it holds no plan assets in a trust (29 CFR 2520.104-20). A plan that files one year and then sits between 80 and 120 participants may keep filing the same way the next year (29 CFR 2520.103-1). That is why some companies under 100 still have a public filing. This 100-participant rule is not the state large-group line. Large group health insurance. It is also not the IRS 50-employee test. Applicable large employer.
What to check in the PDF
- Participants at the start and end of the year, on the main Form 5500. That is the filer’s participant count. It is not payroll headcount.
- Each Schedule A. One per insurance contract. Note the carrier, the contract number, and the policy period dates. The plan’s renewal date is the day after the latest medical Schedule A policy period ends. That day can differ from the Form 5500 plan year.
- Part I carrier-reported broker commissions and fees. Lines 2 and 3. Those dollars are what the carrier paid on that contract. How to read Schedule A broker pay.
- Part III premium and charges. Line 9 if the contract is experience-rated. Line 10 if it is not. Line 8 shows whether dental, vision, or life is bundled on the same contract. Part II is investment and annuity information, not the medical premium.
- Several years, side by side. Contract numbers carry forward. A carrier that stayed is visible. Whether anyone else was quoted is not.
The combined peer set behind the Health Plan Visibility Studies is 52 Texas electrical, plumbing, and HVAC contractors. Median carrier-reported broker pay in that set is 5.3% of medical premium, or $29 per participant per month. Median medical premium is $6,094 per participant, with a 10th to 90th percentile of $3,802 to $9,972. Use those figures only after the Schedule A you opened is a medical contract, not a bundle.
Where a public read sits in the work
A Form 5500 public-filing read is an optional Step 0 before Step 1. You can do it yourself with the steps above, or send the company name to aloha@mattragudo.com and I will send back a one-page read from the public record. Nothing in that read uses your private documents. It is not an analysis of the live plan, and it is not an eighth step.
The seven steps start at Step 1, Introduction, and run through Step 7, All year, every year. For employers with 100 or more employees, Steps 2 to 7 are the Renewal Control Plan, and the Plan Report is its first deliverable. The Plan Report follows a signed broker-of-record letter and the transfer, usually about a month. Employers with 50 to 99 employees get the same seven steps. Group health insurance for employers with 50 to 500 employees.
Pay is carrier commission, often set in the rates the carrier files with the state, and it is not billed to the employer. Every dollar paid on the contract is disclosed in writing, in dollars and per employee, before the plan goes through, for the current plan and every option quoted. How I’m paid.
Advisory analysis, not legal or tax advice.
Questions people ask
Where do I search a Form 5500?
Use the Department of Labor’s EFAST2 Form 5500 Search at https://www.efast.dol.gov/5500Search/. Search the Employer Identification Number first. The FOIA bulk datasets on dol.gov are the same filings, in files, when you need more than one plan year at a time.
When does an employer health plan have to file?
Generally when the plan had 100 or more participants at the beginning of the plan year. 29 CFR 2520.104-20 exempts certain unfunded or insured welfare plans under that count, unless plan assets are held in a trust or another exception applies. A plan between 80 and 120 participants may keep filing the way it did the year before.
Why does a search by company name miss the filing?
The sponsor name on the filing is the legal name on the EIN, which may be a parent or a holding company, not the DBA on the door. Welfare plans are usually numbered 501 and up. Retirement plans are usually numbered 001. Filter before you decide there is no filing.
Why is the newest filing a year or two old?
Form 5500 is due seven months after the plan year ends. Form 5558 extends that to nine and a half months. A calendar-year plan’s 2024 filing can still be the newest public file well into 2026. The renewal you are holding is newer than the filing.
What do I check once the PDF is open?
On the main form, participant count at the start and end of the year. On each Schedule A, the carrier and contract, the policy period (the real renewal date is the day after the latest medical policy period ends), Part I carrier-reported broker commissions and fees, and Part III premium and charges, including bundled dental, vision, or life. How to read Schedule A broker pay.
Is a Form 5500 read the same as a Plan Report?
No. A public-filing read uses only the public record. It is an optional Step 0 before Step 1. It is not an eighth step. The Plan Report follows a signed broker-of-record letter and the transfer, usually about a month, and it is written from the carrier’s own data.
I built and sold a health insurance agency: grew it to 60 agents in about 3 years, then sold it. Licensed insurance agent since 2014: Texas license 2501238, NPN 17369817.
The public filing is Step 0, if you want it.
A Form 5500 public-filing read is optional beforehand. It is not an eighth step. Approve the engagement letter and sign the broker-of-record letter any time of year. The Plan Report follows a signed broker-of-record letter and the transfer, usually about a month, and it is written from the carrier’s own data. How switching brokers works.
Questions first? Email aloha@mattragudo.com or book a 30 minute call.
Sources
- U.S. Department of Labor, EBSA EFAST2 Form 5500 Search. efast.dol.gov/5500Search/
- U.S. Department of Labor, Form 5500 public datasets (FOIA). dol.gov/agencies/ebsa/about-ebsa/our-activities/public-discl …
- 29 CFR 2520.104-20 (limited exemption for certain small welfare plans). ecfr.gov/current/title-29/subtitle-B/chapter-XXV/subchapter- …
- 29 CFR 2520.103-1 (including the 80 to 120 participant filing rule). ecfr.gov/current/title-29/subtitle-B/chapter-XXV/subchapter- …
- U.S. Department of Labor, Form 5500 filing instructions and forms (welfare plan numbers start at 501). dol.gov/agencies/ebsa/employers-and-advisers/plan-administra …
- IRS, About Form 5558 (extension of time to file certain employee plan returns, including Form 5500). irs.gov/forms-pubs/about-form-5558
- U.S. Department of Labor, Schedule A (Form 5500) 2024. dol.gov/sites/dolgov/files/ebsa/employers-and-advisers/plan- …