Is this a MEWA? Is a Form M-1 required?

[Miner88]

Several unrelated colleges contribute money to a trust to pay for health insurance benefits. Each college has its own plan document and contract with the insurance company. They each file 5500s separately. They pay a funding rate into the "consortium's" trust account, and claims and expenses are paid from the trust. They also maintain a reserve in the trust account. A single TPA handles claims for the consortium.

Is this a MEWA that requires filing of the Form M-1? Does the consortium itself (as opposed to each college) have to file a form 5500?

Any thoughts would be appreciated!

[GBurns]

I do not know the answer but the arrangement raises questions.

If each college has its own plan document and contract with the insurance company, Why have the "consortium's" trust account?

They each file a separate 5500 so in showing the assets and values they have to pro-rate to get the amount attributable to each particular college. Why have a common account?