As many of you probably know, the Schedule A on the form 5500 provides detailed information on an insurance policy: the carrier, any brokers involved, fees and commissions, premiums, policy features and renewal dates, etc. Most of this information is supposed to be provided by the carrier to the party actually filing the form.
What you might not know is that, at the very bottom of the Schedule A, there’s a little checkbox that asks whether or not the insurance carrier provided all of the information they were supposed to. A box where the filer can say, “It’s not my fault I’m not compliant! The carrier did it!”
Whether the DOL enforcement office takes pity on those filers I cannot say. What I can say is which carriers are prone to making the most mistakes.
I looked at 50,000 large health policies, and identified the top carriers involved in that market (those carrying more than 100 policies).
Here’s the list of carriers who were cited most often for failing to provide information:
Yikes! In terms of what these errors actually were, the most common by far was failing to provide the address of a broker, but some carriers committed more egregious sins like not reporting claim amounts or lives covered. Some didn't send a Schedule A at all.
This can be a major headache for a plan sponsor or administrator as they attempt to scramble at the zero hour for this information. Be alert!