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MEWA state registration for Fully Insured Group Life?


Guest VolBenefitsGuy
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Guest VolBenefitsGuy

Consider a MEWA plan (not a bona-fide group or association), not subject to ERISA, where no M-1 is required to be filed. MEWA / plan sponsor offers only fully-insured group life, on a voluntary basis to eligible business owners. The policy is issued by a national carrier licensed to operate in all 50 states. The plan is not administered by a trust.

For those states outside the policy situs-state, where covered business owners reside, does the MEWA need to register? It seems that most states registration and model law requirements are concerned about Medical insurance benefits and/or self-insured MEWAs.

Any direction about how to assess NAIC model laws and state regs for fully-insured, non-medical benefits offered through MEWAs would be much appreciated!

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  • 1 month later...

It seems like it would be easy to characterize such arrangement as an insured plan and not as a MEWA but as an insurance contract. Has the policy been filed with the states which require it? (Some states require privately issued policies to be filed, while others don't). Have you spoken with the regulators in your state? This seems like a good place to start. Some insurance departments treat NAIC like it is their boss and others look at their model laws and think, "Well, that's one way to do it." A review of other NAIC model laws will show many implementations of all or part of the model law based upon their own values and perspective.

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I am wondering why it is referred to as a MEWA and also about the wording used by the poster. I get the feeling that there is much more that was not disclosed.

George D. Burns

Cost Reduction Strategies

Burns and Associates, Inc

www.costreductionstrategies.com(under construction)

www.employeebenefitsstrategies.com(under construction)

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