Executive Summary: Multiple Employer Welfare Arrangements (MEWAs) must file a Form M-1 annually and shortly after inception. The annual Form M-1 filing deadline for the 2015 calendar year is March 1, 2016.

Overview: Generally, a MEWA is an arrangement that offers medical benefits to employees or their beneficiaries of two or more employers. MEWAs must comply with certain disclosure and annual filing requirements, as well as certain state-based insurance regulations.

MEWAs arise in several contexts. Health coverage provided to worksite employees by a Professional Employer Organization (PEO) might be considered a MEWA if the PEO provides coverage to multiple clients, and where the clients are determined to be the common law employer of the worksite employees. Additionally, an employer might inadvertently create a MEWA following a corporate transaction if it continues to provide health and welfare coverage to employees who are transferred to an unrelated buyer.

Filing Deadline. Most MEWAs must annually file a Form M-1, usually in March. This year, the filing deadline for the 2015 Form M-1 is March 1, 2016. An additional 60-day, one-time extension to file will automatically be granted if the administrator of the MEWA requests an extension in accordance with the Form M-1 instructions.