“The US Department of Labor (DOL) has proposed changes to the Form 5500 and schedules that will affect ERISA Title I group health plans of all sizes, but small group health plans should be especially aware of the changes. Certain small group health plans (fewer than 100 participants) are currently exempt from filing the Form 5500 Annual Return if they are fully insured, unfunded, or a combination of these. Under the proposed Form 5500 changes, these plans would no longer be exempt and all group health plans covered by Title I would be required to file a Form 5500 including a new Schedule J, Group Health Plan Information. This new schedule would drastically expand the group health plans information gathered.” (Leonard Street)