Employer maintains a self-funded health plan for >100 employees.
The plan is not part of a multi-employer benefit plan that files 5500’s on behalf of all employers.
They use the services of a TPA
There is no trust account for the plan. Benefits are paid entirely from the general assets of employer and stop-loss insurance.
Employees do not make contributions to a trust account. However, employees do pay a monthly "premium" to employer
Question: Is this subject to the Schedule H and audit requirements?