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This Web site contains a compilation of more than a thousand consumer finance  columns written by Tony Novak from the 1980s through 2006, updated and reformatted for maximum usefulness today.  New material was added after 2010.

Content is the opinion of the author and does not represent the position of any other person or entity. Information is from sources believed to be reliable but cannot be guaranteed.

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Form 5500 for small business

originally posted: 11/22/2006  reposted: 2/18/2011 This post has not been recently reviewed or revised by the author and may be out of date. If you notice an error or are in doubt, please send a new question by email or ask for an update. Email

Q: Does an HRA (35 employees) have reporting requirement ( Form 5500)? This is an employer-administered plan. Does the IRS Notice 2002-24 mean that an educational assistance (like Section 127) plan no longer needs to file Form 5500 or will have to file but with out Schedule F?

A: The instructions for Form 5500 make it clear that small business welfare plans (that provide health and education benefits) do not need to file a Form 5500. See for more information. If the HRA provides uninsured benefits, then claim administration is required by a third party. The claim verification report is not filed with the DOL or IRS, but is required to uphold the tax-free status of these specific benefits. Additional resources on HRA plan accounting are available at


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