I have a client that has a welfare benefit plan, is self-insured and has stop-loss coverage. They have recently found that there were commissions paid on the stop loss coverage in 1998 and 1999. They have not filed schedule A's for this coverage. Does a self-insured employer need to file schedule A's on their stop loss coverage?

Actually if you look at Schedule A Part II item 7 i you will see that this item is labeled Stop loss ( large deductible). The instructions to this item states in effect that if the stop loss insurance premium is paid for out of the general assets of the company they are not plan assets and not reportable on Schedule A.

Actually a Sch A does have to be filed in such a situation if the plan is an ERISA plan and a Form 5500 is required for the plan. Since a self-insured plan (by it's nature) is never fully funded, then some benefits will always be paid from the general assets of the employer.