DOL Releases 2021 Annual Self-Insured Health Plans Report to Congress, Analyzing 2018 Data

The DOL has made available its required annual report to Congress on self-insured health plans. The report 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. The 2021 report is based on 2018 Form 5500 filings.

Approximately 60,500 health plans covering about 78 million participants filed a Form 5500 for 2018. The total number of plans increased by nearly 5% from 2017. According to the report, the number of self-insured plans grew most significantly, at over 8%. However, the breakdown of plan types remained largely consistent with other recent years: about 42% of plans were self-insured; 51% were fully insured; and 7% were a combination of insured and self-insured. The number of participants in self-insured plans rose from 34 million (in 2017) to 35 million (in 2018)—about 45% of participants in all plans. Although just 7% of plans were combined insured/self-insured, these plans covered about 36% of participants. In contrast, the 51% of plans that were fully insured covered only 19% of participants.

The report’s appendices provide further analysis, including information about plan funding. Appendix A notes that nearly 75% of the reported self-insured plans covered 100 or more participants and did not operate a trust. In addition, Appendix A now includes a multiple employer plan category, reflecting a change in how the DOL classifies plans by sponsor type for purposes of the report. [EBIA Comment: Prior to the 2020 Report, Appendix A classified plans only as single employer or multi-employer, although Form 5500 has long included a check box for multiple employer plans.] As in previous years, Appendix B specifies 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. The report notes a decline over time in the percentage of plans (both self-insured and combined insured/self-insured) that reported having stop-loss insurance but suggests that the report’s data likely underestimates the prevalence of stop-loss insurance.

EBIA Comment: Many group health plans are not required to file Form 5500—including plans with fewer than 100 participants that are unfunded, insured, or a combination of both and most governmental or church plans (which typically are not subject to ERISA). Thus, the DOL acknowledges that the report’s usefulness in identifying self-insurance trends is limited. 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 upcoming webinar “Form 5500 for Health and Welfare Plans: Preparation and Filing” (live on May 6, 2021).

Contributing Editors: EBIA Staff.