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MEWA & 2014 Form 5500

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The Form M-1 asks whether the entity is a plan MEWA or a non-plan MEWA. However, the 2014 Form 5500 does not make any distinction between the two The instructions to the 2014 Form 5500 simply says that the MEWA file the forms and attach a list of the employers, their EINs and an estimate of each employer's percentage of contributions.

So the $ 64 question is, in the case of a non-plan MEWA, does each employer have to file their own Form 5500. An argument could be made (a bad result for the employers) is that the non-plan MEWA is a DFE and each employer has to file their own Form 5500. Assuming the non-plan MEWA is self funded with a trust, there would be no exemption from the filing requirements for each employer regardless of size since the plan would be "funded."

As a practical matter, each employer would not be able to complete the financial data on the Form 5500 and those with over 100 participants would not be able to obtain an audit reporting listing their own claims, etc. In short, we do not see how the individual employers would be able to comply with the reporting requirements. Our review seems to strongly suggest the Form 5500s are being filed at the MEWA level and individual employers are not filing their own Form 5500s.

Any insight would be appreciated!!!!!

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