December 5, 2018

Department of Labor to MEWAs: Ten Tips for Filing the Form M-1

On December 3, 2018, the Department of Labor (DOL) released the 2018 Form M-1 and accompanying document “10 Tips for Filing Form M-1 for Association Health Plans and other MEWAs that Provide Medical Benefits.” Form M-1 is required for all Multiple Employer Welfare Arrangements (including AHPs) that provide medical benefits; a Form M-1 must be filed electronically. To access the online filing system for the M-1, please click here.  For more information about MEWAs, check out the dashboard.

The 10 Tips for Filing Form M-1*:

  1. A MEWA must file a Form M-1 before starting to “operate.” Operating includes activities such as marketing, soliciting, or offering to provide medical care benefits to eligible participants.
  2. Use the correct form based upon the “plan year” the MEWA follows.
  3. Only MEWAs offering medical care must file.
  4. A MEWA may have to file more than one Form M-1 in a calendar year based upon events.
  5. Be sure to indicate the appropriate type of filing.
  6. Complete all required identifying information.
  7. Include information for every state in which a MEWA operates.
  8. Provide accurate insurance information.
  9. Retain your Form M-1 filing Confirmation Number; this number will be reported on future Form 5500 submissions.
  10. Verify whether you need to also file a Form 5500; a MEWA that is also an employee benefit plan under ERISA (i.e. an AHP) must file both a Form M-1 and a Form 5500.

*Be sure to reference the instructions for completing the Form M-1, beginning on Page 6 of the PDF, accessible here.

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