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Form 5500 reporting requirements for various types of insurance products.

One of the tricky concepts with the Form 5500 is understanding which insurance products will / will not appear on the filing.  In this article we go into a few examples of what you can encounter when reviewing this information in BenefitFlow.  To cut to the chase: an employer is required to report any and all employee benefits policies they have with carriers.  Important caveat: employers that pay medical claims out of pocket (i.e. self-funded aka self-insured), will not have a major medical policy to report. Medical Policies: All group medical policies must be reported on the Form 5500.  For example if you click on any “fully-insured” employer in BenefitFlow, you should find their major medical policy on their profile.  This will include the data on the number of members covered by the policy, the policy renewal date, the premiums paid, and the commissions paid to the broker / consultant. We define “Medical Policies” as any policy that appears on the Form 5500 as: Health, HMO, PPO or Prescription Drug. In the example below, it looks like Upwork has medical policies with both Anthem and Kaiser.
Screenshot of Upwork’s Form 5500 profile in BenefitFlow, displaying medical policies with Anthem and Kaiser listed as carriers.
Non-Medical Policies: All non-medical insurance products must also be reported on Form 5500.  Caveat: in cases where the employee is the policyholder and the employer simply facilitates access to the insurance (such as through payroll deduction) but does not contribute to the plan or have any administrative role in it, then these policies are generally not considered part of the employer’s benefit plan framework and thus not reportable on the Form 5500. We define “Non-Medical Policies” as any policy that appears on the Form 5500 as: Dental, Vision, Life Insurance, AD&D, Disability, Stop Loss, Critical Illness, Wellness/EAP, Business Travel, FSA/HSA/HRA, or Other. Let’s use Upwork again as an example.  It looks like they have various voluntary products placed with MetLife and Vision Service Plan
Screenshot of Upwork’s Form 5500 profile in BenefitFlow, displaying voluntary products with MetLife and Vision Service Plan listed as carriers.
Self-Funded Products: If an employer pays their medical claims out of pocket (i.e. self-funded), they will not have a group medical policy to report on the Form 5500.  However, they will still be required to report their non-medical products. Let’s use Carilion Clinic as an example of a self-funded group.  No Medical Policies were reported on their Form 5500, because in all likelihood (given their size), they are self-funded as opposed to purchasing a group medical policy.  However, you can see they reported all of their non-medical policies, which indicates a strong relationship with Aon.
Screenshot of Carilion Clinic’s Form 5500 profile in BenefitFlow, displaying non-medical products with Aon listed as the carrier.
Fees to Service Providers: One unique reporting requirement for certain* self-funded groups are fees paid to service providers.  A ‘Service Provider’ can include TPAs, carriers (being paid ASO fees), PBMs, legal counsel, consultants, actuaries, among others.  Using Carilion Clinic as an example, they meet the fling requirement and we can see they use Aetna as the administrator for their self-funded health plan.
Screenshot of Carilion Clinic’s Form 5500 profile in BenefitFlow, displaying fees paid to service providers with Aetna listed as the administrator.
*Reporting Requirement: If a benefit plan is a) structured as a trust and b) pays service providers out of plan assets, the employer is required to file a ‘Schedule C’ to the Form 5500.  We observe that roughly 20% of employers meet this filing requirement.
Last modified on February 12, 2026