Why filings get flagged
Form 5500 data is public, structured, and compared year over year. That combination means the first review of your filing is almost never performed by a person — it is performed against the prior year's numbers and against peer plans of similar size.
The practical consequence is that internal inconsistency is more dangerous than an unflattering number. A plan that reports a real problem consistently draws less attention than a plan whose participant count moves in a direction its schedules do not support.
Participant counts that do not reconcile
Beginning-of-year counts should tie to the prior filing's end-of-year counts. When they do not, the filing invites a question the plan sponsor usually cannot answer from memory a year later.
- Counting only enrolled employees when the plan definition includes eligible-but-waived participants.
- Dropping COBRA and retiree participants from one year to the next without explanation.
- Crossing the 100-participant line without adding the audit or schedule data the threshold requires.
Missing schedules and attachments
Schedule A and Schedule C errors are common in self-funded plans because sponsors assume a self-funded arrangement has nothing to report. Stop-loss coverage, ASO arrangements, and indirect compensation to brokers and TPAs frequently do.
The fix is procedural: request vendor disclosures early, and reconcile the numbers your service providers report against what appears on the filing before it is submitted.
Late filings and the cost of waiting
Penalties for a delinquent filing accrue daily and can dwarf the cost of the filing itself. The Delinquent Filer Voluntary Compliance Program exists precisely because voluntary correction is dramatically cheaper than being found.
If you know a prior-year filing is missing or wrong, the decision point is now, not at the next deadline.
What to do before you file
Build a one-page reconciliation: prior-year end counts, current-year beginning counts, every vendor with a compensation disclosure, and the plan document provisions that define eligibility. Nine out of ten filing problems surface in that exercise.
Want this reviewed against your actual plan?
We'll look at your documents, contracts, and filings and tell you plainly where the exposure sits.