Merging a MEP into a Single ER Plan

[Crocker]

This is new for me and any insight shared would be appreciated. Our company purchased an organization with a MEP last year and we would like to merge the 20 facilities/employer plans into our single ER Plan.   Can we handle it like a standard trust-to-trust conversion - addressing any protected benefits?  I heard there are special consideration for MEPs, however I couldn't locate any conversation on unique issues we need to consider.   Thank you.

[justanotheradmin]

I think some clarification on the facts would be helpful. 

Is this correct:

Tier 1: Your Company

Tier 2: Acquired Co. wholly owned subsidiary, or to be absorbed into Your Co. 

Acquired Co. - Lead Sponsor of a MEP

Tier 3: 20 other companies that participate in the MEP

Who owns those 20 companies? If they aren't a related employer group (control group, affiliated service group etc) merging them into a single employer plan doesn't change anything. 

If you have unrelated employers participate in a single plan, its a MEP. Even if it isn't marketed as a MEP, it's still a MEP. A single ER plan only exists if all of the business entities are a single employer (such as a control group). 

[Crocker]

Thank you - your assumptions are correct and it sounds like we might not be able to merge them into out Plan.  Each of the 20 facilities are jointly owned with 20  separate outside partners who work at the facility as well.

[justanotheradmin]

You can probably merge them all you want, and maybe have good reasons to do so (related businesses, payroll, management etc). but if they are not part of single employer, each entity would need to have the compliance testing performed separately, as if they were truly stand alone. and I'm not sure what the existing MEP document / agreement says. It would be a pain if you have to get each of the 20 employers to agree to the plan change. 

You may have other efficiencies gained by keeping it a multiple employer plan, such as investment or recordkeeping pricing, audit cost, plan documents costs, etc. But it won't be treated as a single employer plan. 

Single Plan /= single employer plan

Good luck.