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DOL Releases 2019 Annual Self-Insured Health Plan Report to Congress, Analyzing 2016 Data

EBIA  

EBIA  

Report to Congress: Annual Report on Self-Insured Group Health Plans (Mar. 2019); Appendix A, Group Health Plans Report: Abstract of 2016 Form 5500 Annual Reports Reflecting Statistical Year Filings (Mar. 2019, v. 1.0); Appendix B, Self-Insured Health Benefit Plans 2019: Based on Filings Through Statistical Year 2016 (Jan. 7, 2019)

Report

Appendix A

Appendix B

The DOL has made available its annual report to Congress on self-insured health plans. The report, required by the Affordable Care Act, provides general information about the characteristics of private-sector self-insured health plans (including number of participants, benefits offered, funding arrangements, and plan assets), as well as publicly available financial information about their sponsoring employers. It updates the DOL’s 2018 report (see our Checkpoint article) and is based on 2016 Form 5500 filings.

Approximately 56,200 health plans covering 75 million participants filed a Form 5500 for 2016. The number of plans increased by nearly 3% from 2015. Consistent with 2015, about 42% of plans were self-insured; 51% were fully insured; and 7% were a combination of insured and self-insured. The percentage of self-insured plans decreased slightly, and the number of participants in self-insured plans rose slightly from 34 million (in 2015) to 34.5 million (in 2016). Although just 7% of plans were combined insured/self-insured, these plans covered almost 37% of participants. The report’s appendices provide further analysis, including information about plan funding. Appendix B notes that there is no consistent evidence that the financial health of fully insured plan sponsors is better or worse than self-insured or combined insured/self-insured plan sponsors.

EBIA Comment: The DOL acknowledges incompleteness of the information due to inherent challenges in data collection, including the fact that the Form 5500 data includes only plans with 100 or more participants or assets held in trust, and does not capture data for governmental or church plans. As a result, the report’s usefulness in identifying self-insurance trends is limited, especially among small plans that are not required to file Form 5500 because they are unfunded, insured, or a combination of both. Unlike last year, the report did not mention proposed changes to the Form 5500 that would result in the collection of more detailed funding and benefit information (see our Checkpoint article); the future of those proposals is currently unclear. Instead, the report noted the DOL’s focus on expanded group health plan access for small businesses through association health plans (AHPs), which are expected to be separately quantified in the report in the future. (Note, however, that a court recently vacated key provisions of the DOL’s regulations on AHPs; see our Checkpoint article.) For more information, see EBIA’s Self-Insured Health Plans manual at Sections IV.B (“Financial Considerations”) and IV.E (“Prevalence and Characteristics of Self-Insured Health Plans”). See also EBIA’s Health Care Reform manual at Section XXXVI.E (“Annual Report on Self-Insured Plans (Using Information From Form 5500s)”) and EBIA’s ERISA Compliance manual at Section XXII (“Annual Form 5500 Reporting to the DOL”). You may also be interested in our webinar “Form 5500 for Health and Welfare Plans: Preparation and Filing(recorded 5/8/19).

Contributing Editors: EBIA Staff.

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