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Found 9 results

  1. (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!
  2. I have a client that has had a MEWA since 2008. They never filed the Form M1. They wanted to know of examples of penalty fees others have faced in similar situations on filing Form M1s late. Any input would be greatly appreciated. The DOL will only state what could happen on the fees. Many thanks for your help.
  3. 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!
  4. 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.
  5. Hello, If a MEWA plan is level funded, can it possibly be considered fully-insured? And if it has not existed for a year, does that give us any out from being considered a MEWA? Seller is part of a MEWA and hasn't been in compliance with state insurance laws.
  6. Hi all, Does anyone have recent (i.e., post-2013 M-1 regulations) experience with late filing penalties for the M-1? Assuming there's no fraud involved, and an employer unintentionally created a MEWA, does the DOL actually assess the $1,500/day penalty? There does not appear to be a DFVCP-like program to self-report and mitigate the penalties, and we are struggling to figure out how the DOL handles this in practice. We've tried the DOL number in the M-1 preamble multiple times, with no luck. Does anyone have any experience with this, or a contact within the DOL we could reach? Thanks much!
  7. The MEWA definition in ERISA 3(40) (29 USC 1002(40)) provides that a MEWA is an employee welfare benefit plan established/maintained for the purpose of offering/providing any welfare plan benefit to the employees of two or more employers (including one or more self-employed individuals)... My question is how to define "self-employed individuals" for MEWA purposes. 401© defines the term, but I'm unsure whether that can properly be incorporated into the MEWA definition. Thank you in advance for your assistance.
  8. A MEWA that is not an ERISA welfare benefit plan can file one Form 5500 on behalf of all employers who purchase benefits from the MEWA if the MEWA is a group insurance arrangement ("GIA"). A GIA is an arrangement that: 1. provides benefits to the employees of two or more unaffiliated employers; 2. fully insures one or more welfare plans of each participating employer; 3. uses a trust or other entity as the holder of the insurance contracts; and 4. uses a trust as the conduit for payment of premiums to the insurance company. See DOL Reg. 2520.104-43 and 2520.104-21. I'm trying to figure out what kind of trust must be used (numbered paragraph 4 above) in order for an arrangement to qualify as a GIA. Can the trust be a taxable trust, or must it be a tax-exempt trust? For what purpose must the trust be established? It is only for accounting purposes? Any insight or thoughts are greatly appreciated!
  9. If the DOL no longer required employer associations to be bona fide (AKA have commonality and control over the plan), what entities would qualify as MEWA under the phrase "any other arrangement"? ------------------------------------------------------------------------------ People are correct in that the commonality requirement for pensions is not explicitly stated in ERISA. My thought, is congress may have ratified the DOL's position requiring employer associations to possess commonality and control by adopting the 1983 amendment defining a MEWA: Essentially, unless some entities would still be considered to be a non-EWBP MEWA without the commonality and control requirements, then the definition of employer association must require some form of commonality and control, otherwise part of the statute would be superfluous. Thoughts?
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