February 21, 2018
The DOL recently issued the 2017 version of Form M-1. As background, Form M-1 must be filed by multiple employer welfare arrangements (MEWAs) and certain entities claiming exception (ECEs). The Form M-1 allows those entities to report that they complied with ERISA's group health plan mandates.
While few substantive changes to the Form M-1 have been made, this year's Form M-1 instructions have been updated to reflect changes in the maximum per-day penalties that can be applied for failure to file (including late or inaccurate filings). Specifically, the maximum penalty for a MEWA administrator who fails to file a complete and accurate Form M-1 has been increased to $1,558 per day for penalties assessed after Jan. 2, 2018.
Therefore, MEWAs should work with their advisor and service vendors to ensure compliance with ERISA and M-1 filing obligations.
2017 Form M-1 Instructions »