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Program of Administrative Services Is Neither a Welfare Plan Subject to ERISA Nor a MEWA, Says DOL
ERISA Lawyer Blog 
[Guidance Overview] Mar. 22, 2017
"[DOL Advisory Opinion 2017-01A] concluded that the Program is not an employee welfare benefit plan. It said that such a plan does not include a program maintained by an employer (or group or association of employers) which ... has no employee participants and does not provide covered benefits to employees or their dependents. Rather than being established or maintained for the purpose of providing welfare benefits to participants and beneficiaries, the Program operates so as to facilitate the efficient establishment and operation of employee benefit plans by employer-members."
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