HELP! How would you fix the following.

Welfare plan adopted in 1980 for group of union employees (under 100). Had trust that paid claims - so it was self-funded. 1996 the plan opted to start buying insurance rather than pay claims. Now benefits are fully provided by insurance. Trust is still there and growing. Employer contributions are more that the insurance premiums.

Plan has never been amended, Plan has never filed 5500, Plan did not file to be VEBA.

Any suggestions?