Health & Welfare Plans Newsletter
BULLETINDecember 3, 2018
Text of 2018 DOL Form M-1 for Use by Association Health Plans and Other MEWAs (PDF)
"The Form M-1 is used to report information concerning a multiple employer welfare arrangement (MEWA) that provides benefits consisting of medical care ... and any entity claiming exception (ECE). Reporting is required pursuant to ERISA sections 101(g), 104(a), 505 and 734 of [ERISA]." [Editor's note: Form M-1 is filed electronically
.]
Employee Benefits Security Administration [EBSA], U.S. Department of Labor [DOL]
DOL Releases 2018 Form M-1 for Use by Association Health Plans and Other MEWAs
"Since April 11, 2000, MEWAs that provide medical coverage, including AHPs, have been required to file a Form M-1 with the Department. On June 21, 2018, the Department published a rule that allows more groups and associations to form AHPs and also allows working owners without other employees (including sole proprietors) to join AHPs and receive health coverage for themselves and their families. AHPs established pursuant to this new rule constitute MEWAs and, as such, are required to file the Form M-1.... All MEWAs that provide medical benefits, including AHPs that intend to begin operating under the new rule, are required to file an initial registration Form M-1 at least 30 days before engaging in any activity." Employee Benefits Security Administration [EBSA], U.S. Department of Labor [DOL]
"[N]o one should be marketing, operating, or administering a MEWA that offers medical care benefits, unless it has filed an M-1. If you learn of such a filing failure, please notify [EBSA] immediately and exercise extreme caution before enrolling or participating in the arrangement.... Any business or individual considering enrolling in coverage through an AHP can visit the Department's webpage and use the Department's electronic Form M-1 search tool
... to determine whether the AHP has appropriately registered with the Department and made any other required M-1 filings.... A MEWA that offers medical benefits [including a newly created association health plan] must file a Form M-1 at least 30 days before engaging in any activity including,
but not limited to, marketing, soliciting, providing, or offering to provide medical care benefits to a participating employer or employees, including working owners."
Employee Benefits Security Administration [EBSA], U.S. Department of Labor [DOL]
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