Challenge: The Employee Retirement Income Security Act (ERISA) covers retirement, health, and other welfare benefit plans and ensures that managers of these plans meet certain standards of conduct and reporting requirements. As the agency charged with enforcing the provisions of ERISA, the U.S. Department of Labor (DOL) Employee Benefits Security Administration (EBSA) sought to understand the population of Multiple Employer Welfare Arrangements (MEWAs) and Certain Entities Claiming Exception (ECEs) that file the Form M-1. MEWAs are employee benefit plans that provide one or more employee welfare benefits to employees of two or more employers that are not part of a collective bargaining agreement, and ECEs provide employee benefits based on collective bargaining agreements.
Solution: DOL contracted with Summit to analyze the Form M-1 filing population for filing years 2010 through 2013 to understand how key attributes of the Form M-1 filing population have changed over time, attributes of the subpopulation that also files the Form 5500, and information regarding insurance providers who serve MEWAs and ECEs. The team found that the number of unique filers per filing year has remained constant over time at around 400, while the number of filings increased in 2012 primarily due to extensions filed. Filers explicitly reported their entity type for the first time in 2012. In that year, 92.5% of filers identified as Plan MEWAs, 4.7% as Non-Plan MEWAs, and 2.8% as ECEs. The distribution of filers was very similar in 2013. A complete report can be found here.