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(Sorry, I posted this in "other kinds of welfare benefit plans" as well, but I'm not sure that's the right place for it. So I'm posting it here as well.) Stumbled on this forum, what a great wealth of wisdom! I'm a union rep and we are considering starting a healthcare plan for our members. Instead of the various employers having their own healthcare plans for our members, the employers are going to give us the money and we will provide the healthcare plan for our own members. I believe we will need to start a VEBA and a MEWA, but I am uncertain as to how much we will need to allocate for start-up costs (e.g. legal advice, documents, etc.). We have 10-15k local union members. I'm assuming it will cost $500-$1mm to start up and at least 1.5 years before we can go live. Am I even in the ballpark? Anyone know how much it will cost us to get this started? Any help is much appreciated!

Stumbled on this forum, what a great wealth of wisdom! I'm a union rep and we are considering starting a healthcare plan for our members. Instead of the various employers having their own healthcare plans for our members, the employers are going to give us the money and we will provide the healthcare plan for our own members. I believe we will need to start a VEBA and a MEWA, but I am uncertain as to how much we will need to allocate for start-up costs (e.g. legal advice, documents, etc.). We have 10-15k local union members. I'm assuming it will cost $500-$1mm to start up and at least 1.5 years before we can go live. Am I even in the ballpark? Anyone know how much it will cost us to get this started? Any help is much appreciated!

Background: Client is in the middle of selling a division and will be keeping those employees in it's medical plan for the rest of the year to avoid disruption, thus creating a self-insured MEWA with two employers for this short period. I'm trying to determine the potential risks and requirements of keeping these employees in the plan for the rest of the year under Tennessee law. So far I've found the applicable rules and regulations (Tenn. Comp. R. & Regs. 0780-01-76), but I'm a little confused as to if these regs apply to a two employer MEWA because 1) the regs say they apply to "self-insured qualified" MEWAs and 2) then go on to define a qualified MEWA as consisting of ten employers. Anyone have any insight here? Would really appreciate it - feel like I'm just spinning my wheels at this point.

Any insight on whether sponsors of self-funded health plans are sharing in rebates paid to the TPA when specialty drugs are run through the medical benefit instead the pharmacy program? We are capturing the rebates paid to the PBM when run through pharmacy benefit.

An employer maintains an ERISA-governed group health plan. An employee pays a cafeteria plan’s salary-reduction contribution toward the employer’s cost for the employee’s health coverage. There is no trust. The plan uses no group health insurance contract; every benefit is paid from the employer’s general assets. The employer uses an “ASO” service provider to serve as the plan’s claims administrator. An affiliate of that service provider provides a stop-loss insurance contract. The employer pays upfront amounts described as its maximum liability. If the experience for a year (after some set-asides, including fees, stop-loss premium, an incurred-but-not-received reserve, and some further margins) is more favorable to the employer than what invokes the maximum liability, the service provider returns money to the employer. The people who advise the employer are familiar with ERISA Technical Release 2011-04, which includes a little guidance about whether employees might be entitled to some portion of a health insurer’s rebate. Those advisors disagree about whether employees are entitled to a portion of this “rebate” from an arrangement that involves no group health insurance. • One believes the employees should get a portion that approximates the ratio of the participant contributions to the whole “cost” of the health coverage. • Another believes the self-funding adjustment is wholly the employer’s property, and nothing should be allocated to participants or employees. Who is right? And what reasoning supports the conclusion?