How a benefits broker uses Form 5500 Schedule A to displace an incumbent
Schedule A is the public file roughly 92% of large welfare plans submit every year. The incumbent broker signs it and walks away. A teardown of a real 2,142-life self-funded plan, three wedges that win the meeting, and the query that produces the prospect packet in five minutes.
The setup
A broker has an introduction to the CFO of a 2,100-employee specialty manufacturer. Self-funded medical paid from general assets through an ASO carrier, fully-insured ancillary, life and LTD through a national carrier, a behavioral carve-in, and a vision contract. The incumbent broker has held the account for nine years. The CFO is not actively shopping. The introduction is “happy to take fifteen minutes if you have something specific to say.”
Fifteen minutes is plenty. The disclosure surface for any ERISA-covered welfare plan with 100 or more participants is a public filing. Form 5500 plus Schedule A for every insurance contract, posted to the Department of Labor's EFAST2 system within weeks of filing. The incumbent broker signs these every July. The challenger broker reads them.
Most brokers do not read them. The raw files require ingestion, leading-zero handling on EINs, and joins across the main form, Schedule A, and (when filed) Schedule C before anything useful surfaces. The brokers who do the work walk into the meeting with the CFO's own carrier stack, broker commission rates benchmarked against peers, and a question the CFO has not heard before.
What's actually on file (and what isn't)
Before the teardown, one thing worth being honest about. Most internet write-ups about Form 5500 lead with Schedule H, the financial statement with assets, liabilities, contributions, and benefits paid. Schedule H is real, but it does not apply to most self-funded medical plans. We pulled the numbers:
Filing rates, large welfare plans (100+ participants), 2023
Schedule H is rare because most self-funded medical plans are technically “unfunded” under ERISA: paid from employer general assets rather than a trust. DOL Technical Release 92-01 exempts those plans from Schedule H entirely. The medical claims pass through ASO and never appear on Form 5500.
What does appear on Form 5500, for nearly every large welfare plan: every insurance contract the plan holds (stop-loss when the plan is the policyholder, ancillary life, disability, dental, vision), and the broker commission paid out of each policy. That is Schedule A. It is where the teardown starts.
Schedule C is the second layer. It reports service providers paid $5,000 or more in direct or indirect compensation: TPA, PBM, broker override agreements, consulting fees. About 11% of large welfare plans file it, and when they do, it usually tells the rest of the story.
The teardown
Here is what the public filing for a real 2,142-life self-funded welfare plan produces when every Schedule A contract is joined and the broker commission is computed against peer cohorts. The sponsor name is anonymized; every number is from the most recent filed plan year.
Schedule A teardown, most recent plan year
Five carriers, three with disclosed broker commission, two reporting $0. No Schedule C filed (meaning either no service provider was reported as receiving $5,000+ in direct or indirect compensation, or the filer did not disclose what was paid). No Schedule H, because the plan is unfunded and exempt. Everything that touched an insurance policy is on the page; everything that touched the ASO carrier or the broker as a direct fee from the employer is not. That gap between what is disclosed and what is paid is what the meeting is about.
Three wedges that win the meeting
Three conversations the incumbent broker is not having. Any one of them is enough.
1. Broker commission rate above peer median
The life and long-term-disability contract with the national carrier shows $73,851 broker commission on $736,818 of disclosed charges. That is a 10.0% commission rate on this contract.
Peer cohort for life-benefit contracts at 1,500 to 3,000 covered lives in 2023: 25th percentile 4.8%, median 8.9%, 75th percentile 13.0%. The prospect sits roughly 115 basis points above the peer median.
At the median rate, the same coverage would run about $65,300 in commission. The gap is roughly $8,500 per year on one contract. Small money, but the incumbent broker has held this account for nine years and the CFO has never seen the comparison.
2. The $0 commission line on the largest covered population
The behavioral health ASO contract covers 2,364 lives, the largest single covered population on the filing, and reports $0 broker commission against $34,138 of charges. The expat health contract reports $2,244 commission on $28,044 of charges (8.0%). The other small health carrier reports $0.
A $0 commission line on the largest population is not a clean answer. Self-funded ASO compensation typically sits outside Schedule A and is supposed to be disclosed on Schedule C. This plan filed no Schedule C. That is a question for the CFO, not a closed file.
3. Stop-loss premium per life, when it is on file
No stop-loss carrier appears on this plan's Schedule A. For a 2,000-life self-funded medical plan, the usual explanation is that the employer holds the stop-loss policy directly, which keeps it off the plan-level filing. Worth asking about either way.
When stop-loss is on Schedule A, peer benchmarks are tight: 25th percentile $454 per covered life, median $799, 75th percentile $1,233 (2023, plans with 500 to 5,000 covered lives).
A prospect 30% above peer median on stop-loss has a renewable conversation the incumbent has never raised, because raising it costs the incumbent their override on the stop-loss carrier.
Any one of these gets the next meeting. Pick whichever fits the CFO in the room.
The query
Same teardown, one conversation. Typed into Claude with the Medistill connector attached:
You type
“Pull the Form 5500 history for [Sponsor Name]. Surface every Schedule A carrier with persons covered, charges paid, broker commission, and commission rate. Benchmark each commission rate against peer cohorts of the same benefit type at 1,500 to 3,000 covered lives. Flag any contracts where the rate is above the 75th percentile and any where the commission is $0 on a population above 500 lives. Note whether Schedule C and Schedule H were filed. Build the broker prospect packet.”
What Medistill does under the hood
- Resolves the sponsor by name (fuzzy match) and EIN, handling sponsor-name changes across plan years and the well-known leading-zero EIN truncation issue.
- Joins Form 5500 main and Schedule A across every available filing year, plus Schedule C and Schedule H when attached.
- Surfaces every insurance carrier (medical, dental, vision, life, disability, stop-loss, behavioral) with charges paid, persons covered, broker commission, and broker fees.
- Computes commission as a percentage of charges paid per contract and benchmarks each against the peer cohort for that benefit type and size band.
- Flags above-75th-percentile commissions and suspicious $0 commission lines on large covered populations.
- Returns a packet: prospect summary, carrier stack with commission rates, peer benchmark, compliance and disclosure flags, recommended discussion agenda.
End to end: about five minutes. Every number is sourced and queryable for follow-up.
The prospect packet
Four pages, mostly tables. Cover page is a one-paragraph summary of where the prospect sits versus peers on broker compensation. Page two is the full carrier stack with commission rate per contract. Page three is the peer distribution. Page four is the recommended discussion agenda for the fifteen-minute meeting.
The cover paragraph is the wedge. Built on real numbers from this plan's own filing:
“Your life and LTD contract paid $73,851 in broker commission against $736,818 in disclosed charges, a 10.0% commission rate. Peer cohort for life-benefit contracts at your covered-life count runs 4.8% / 8.9% / 13.0% at the 25th, 50th, and 75th percentile. You sit roughly 115 basis points above the peer median. Your behavioral ASO contract covers 2,364 lives and shows $0 commission, which usually indicates compensation that should be disclosed on Schedule C; your plan filed no Schedule C this year. The attached deck walks through the three contracts worth discussing in the meeting.”
That paragraph is what gets the second meeting. The CFO is reading their own numbers benchmarked against peers, in plain English, before the broker has pitched anything.
How it's done today
The brokers who do this well run through three or four tools and a junior analyst. Each one answers part of the question. None of them answers all of it.
FreeERISA / Form 5500 search portals
$0 to $2K / yearFree or low-cost portals that surface individual filings one at a time. Useful for a single-sponsor lookup. Not built for cohort benchmarking or for stitching ten years of filings into a single trend.
Wrangle 5500 / ERISApedia
$3K-$10K / yearERISA practitioner tools with deeper search and some pre-built reports. Strong on compliance angles. Most brokers use them episodically; the analytics layer is built for ERISA attorneys, not for cohort benchmarking.
EFAST2 bulk download
Free, but rawDOL publishes the full Form 5500 and schedule database in annual CSV exports. Joining Schedule A to the main form across 1.1M plans is real work. Computing commission percentiles by benefit type and size band requires SQL or a competent analyst.
Manual peer benchmark
1-2 days per prospectThe analyst pulls the prospect, then has to find peers of similar size and benefit type, pull their filings one at a time, normalize commission rates, and build a distribution. This is the step that does not happen at scale, which is why the cover-paragraph wedge is rare.
The realistic workflow at most mid-market brokerages is a FreeERISA lookup, a screenshot for the pitch deck, and a qualitative line about “benchmarking against similar plans.” The CFO has seen that pitch before. They have not seen the cover paragraph.
What this unlocks for the producer
The same prospecting workflow, today versus through Medistill:
Today
With Medistill
Cost matters less than cadence here. A producer who can turn a Schedule A teardown around in five minutes runs ten of them before the incumbent has finished the renewal census. The prospect list shifts from “who do I know in the area” to “who in this metro files with above-cohort commission rates or undisclosed Schedule C.”
Pair the teardown with a target list pulled from the same data (self-funded employers in a metro, headcount band, industry, with above-75th-percentile commission rates on file) and the producer has a quarter of warm leads by Friday.
FAQ
Questions brokers and benefits consultants ask before running their first Schedule A teardown through Medistill.
Which Form 5500 schedules matter for a health and welfare plan teardown?+
Schedule A is the primary disclosure for any plan with insured benefits: one row per insurance contract with carrier, premium, persons covered, claims paid, and broker commission. Schedule C reports service providers paid $5,000 or more in direct or indirect compensation: TPAs, PBMs, brokers, consultants. Schedule H is the long-form financial statement but it is only filed by trust-funded plans, which is a small minority of self-funded medical plans (unfunded plans paid from employer general assets are exempt under DOL Technical Release 92-01).
What share of large welfare plans actually file Schedule H?+
In 2023, about 5% of welfare plans with 100 or more participants filed Schedule H. About 92% filed Schedule A and about 11% filed Schedule C. Most self-funded medical plans are unfunded for ERISA purposes and exempt from Schedule H, which means the medical claims pass through ASO without appearing on Form 5500. Stop-loss, ancillary insurance, and broker commission still show up on Schedule A.
How does a broker use Schedule A to displace an incumbent?+
Schedule A discloses every insurance contract the plan holds and the broker commission paid out of each policy. A broker can compute the prospect's commission rate per contract, benchmark it against peer cohorts of the same size and benefit type, and identify above-market commissions or undisclosed lines. Combined with stop-loss premium per covered life, the broker walks into the RFP with the prospect's own numbers and a peer distribution the incumbent has never produced.
What is on Schedule C versus Schedule A?+
Schedule A reports insurance contracts (one row per carrier, with premium and broker commission paid out of the policy). Schedule C reports non-insurance service providers paid $5,000 or more in direct or indirect compensation: TPA, PBM, recordkeeper, consultant, ASO carrier, broker override agreements. The same broker can appear on both, and the totals rarely match what the CFO thinks they are paying.
Why might a self-funded medical plan show no broker commission on its ASO carrier?+
Self-funded medical plans typically pay their ASO carrier a per-employee-per-month administrative fee that is not an insurance premium, so the broker commission line on Schedule A reads $0. The actual broker compensation is captured as indirect compensation under Schedule C when filed, or sits outside the Form 5500 surface entirely (PEPM-based broker fees billed to the employer directly). For a broker walking into the meeting, a $0 commission line on the largest covered population is a question, not an answer.
How long does a Form 5500 teardown take with Medistill?+
A complete teardown of a single sponsor, including every Schedule A carrier across all filing years, every Schedule C service provider when filed, broker commission rate benchmarking against same-size peers, and any compliance flags from the main filing, runs in about five minutes in one conversation. Building a target list of 200 self-funded sponsors in a metro area runs in under a minute.
Are Form 5500 filings public?+
Yes. The Department of Labor publishes all Form 5500 filings and schedules to EFAST2 within weeks of filing. Anyone can download them. Brokers, plaintiffs' attorneys, regulators, and the PBM industry all use this data. Most brokers don't, because the raw files require ingestion and joining across the main form and schedules to be useful for cohort benchmarking.
Run your own teardown
The fastest way to evaluate this is to pick a real prospect. Bring the sponsor name. Ask Medistill to pull the Form 5500 history, surface every Schedule A contract, benchmark each commission rate against same- size peers, and produce the cover paragraph. Compare what comes back to what your team would have built by Monday afternoon.
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