EBIA Weekly Newsletter

DOL Releases 2018 Annual Self-Insured Health Plan Report to Congress, Analyzing 2015 Data

   June 7, 2018

Report to Congress: Annual Report on Self-Insured Group Health Plans (Mar. 2018); Appendix A, Group Health Plans Report: Abstract of 2015 Form 5500 Annual Reports Reflecting Statistical Year Filings (Oct. 2017, v. 1.0); Appendix B, Self-Insured Health Benefit Plans 2018: Based on Filings Through Statistical Year 2015 (Aug. 18, 2017)

The DOL has made available its eighth annual report to Congress on self-insured health plans. The report is required by the Affordable Care Act and 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 2017 report (see our Checkpoint article) and is based on 2015 Form 5500 filings.

Approximately 54,500 health plans covering 73 million participants filed a Form 5500 for 2015. The number of plans increased by nearly 6% from 2014. 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 increased slightly, and the number of participants in self-insured plans increased by 1 million (to 34 million), from 2014 to 2015. The prevalence of self-insurance generally increased with plan size. Despite comprising just 7% of plans, the combined insured/self-insured plans covered 36% 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 unfunded and insured. Like last year, the report notes that proposed changes to the Form 5500 would collect more detailed funding and benefit information, significantly enhancing the DOL’s ability to describe the full universe of self-insured plans and how they compare to fully insured health plans (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 recorded webinar “Form 5500 for Group Health Plans: Preparation and Filing(recorded 5/3/18).

Contributing Editors: EBIA Staff.