Deadline to File Form M-1 for Multiple-Employer Welfare Arrangements (MEWAs)

• Some MEWAs as defined by ERISA
• Some collectively bargained multiple employer programs

The Form M-1 must be filed no later than March 1 following any calendar year for which a filing is required. A one-time extension of time to file will automatically be granted if the administrator of the MEWA or ECE requests an extension.

A MEWA must file a M-1 (MEWA registration) 30 days prior to beginning to operate in a state, withing 30 days of:

• The MEWA begins knowingly operating in any additional State;
• The MEWA begins operating following a merger with another MEWA;
• The number of employees receiving coverage for medical care under the MEWA is at least 50 percent greater than the number of such employees on the last day of the previous calendar year;
• The MEWA experiences a material change as defined by these instructions.

Employee Benefits Security Administration

The Form M-1 is an annual report that must be filed by Multiple Employer Welfare Arrangements (MEWAs). In general, MEWAs are arrangements that offer health and other benefits to the employees of two or more different employers.

Filers should not complete a Form M-1 if the plan does not include Medical Benefits. MEWAs do not include plans determined by the Secretary of Labor to be collectively bargained. Plans claiming this exception without a determination from the Labor Department are considered Entities Claiming Exception (ECEs) and must file for three years following an origination event (which is defined in regulations and in the instructions to the Form M-1).