How to Determine an ERISA Plan Name, Plan Number & Plan Year

February 14, 2018

Employee welfare benefit plans are required to have their own identifying information, which includes a plan name, plan number and plan year. This required information is filed each year with the United States Department of Labor (US DOL) on Form 5500 (if applicable). The formal plan name, plan number and plan year must also be included in the employee welfare benefit plan’s Summary Plan Description (SPD).

Plan Name

Each employee welfare benefit plan must have a primary name. If a plan has a secondary name that it is often referenced by, that information must also be included in the SPD. If an employer has wrapped its employee welfare benefit plans under one ERISA wrap document, the bundled or wrapped plan’s name should be the plan name under which the Form 5500 is filed and should also be the plan name used in the plan documents.

Plan Number

The DOL has specific rules when it comes to assigning a plan number to an employee welfare benefit plan. The number should be assigned by the Plan Administrator or the Plan Sponsor, and should not be used for any other benefit plan the employer is offering. Each plan must have a three-digit number, starting with number 501. Any new plans should be given the next three-digit number available. Making a plan design change does not generally constitute the need for a new plan number. The three-digit plan number, combined with the employer’s nine-digit employer identification number (EIN), creates a 12-digit number used by the DOL to identify that specific employer welfare benefit plan.

Plan Year

Generally, a plan year is defined as the 12-month period based on the calendar year or fiscal year in which benefit records are maintained. Although there are some allowances for short plan years, most plan years are 12 months long starting with the effective date on which the plan started. If all welfare benefit plans are combined under one wrap document, they must all have the same plan year (not to be confused with renewal year or contract year). A review of the plan document and the SPD should reveal the specified plan year. If the plan document does not designate a plan year and there is no available Form 5500 to review, federal regulations issued under HIPAA (and amended by the Affordable Care Act) provide guidance on determining the plan year:

• Use the deductible or limit year used by the plan.
• If there is no annual deductible year or annual limits enforced by the plan, use the policy year.
• If there is no annual deductible year, no annual limit year imposed and the policy is not renewed annually, use the fiscal year of the sponsoring employer.
• If none of the previous guidance applies, use a calendar year.

Learn more: https://www.dol.gov/agencies/ebsa/key-topics/reporting-and-filing/form-5500