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Multiple Plan EINs, Single Trust?

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Health plan has two groups of employees (A & B). Both are currently operating as a single unit under the same trust agreement. They report using the trust's EIN.

Plan sponsor decides to merge group A with another plan--likely in August 2016. Group B will be left behind, but converted to a smaller, fully insured platform.

In order to transition Group B into a fully insured policy and avoid underwriting (group B is fewer than 50 employees), the broker/insurer want a separate EIN for this group.

Can we apply for an EIN for group B now and allow it to continue to operate under the same trust agreement? The idea is to move Group B to a fully insured product as of June 1st while Group A remains on the self-funded platform until it's move in August.

Originally we thought it would be necessary to establish a new trust for Group B in order to spin them off, but the broker says multiple EINs are acceptable under the same trust umbrella.

Thanks in advance.

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  • 4 months later...

If I'm understanding your question correctly, I don't believe multiple EINs in a single trust should be an issue. Unless the ownership between the two sponsoring entities is identical, the Plan would likely become a multi-employer plan which would open it up to additional reporting and disclosure requirements but over all there shouldn't be any legal concerns with the trust being funded by multiple EINs. Just make sure your plan docs are updated/amended accordingly and all required notices (primarily the SMM) are distributed timely. If the Plan becomes a multi-employer plan you will also need to file form M1 next year, which, depending on the number of employers involved, can be a real pain.

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