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Employer Association's Administrative Services Arrangement Is Not an ERISA Welfare Plan or a MEWA
Thomson Reuters / EBIA Link to more items from this source
Mar. 16, 2017
"The program was developed by an association of large employers that sponsor self-insured benefit plans through administrative services only (ASO) agreements with insurance companies.... Noting that a program that has no employee participants and does not offer or provide benefits to employees or their dependents is not an ERISA welfare plan, the DOL concluded that this program is not an employee welfare benefit plan under ERISA Section 3(1) because it has employers rather than employees as participants.... The DOL also determined that the program is not a MEWA under ERISA Section 3(40) because it was not an arrangement established or maintained to provide welfare benefits to employees of two or more employers[.]"

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