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DOL Releases 2011 Form M-1; Proposed Changes to the Form M-1

The Department of Labor recently announced that the 2011 Form M-1 annual report for multiple employer welfare arrangements (MEWAs) is now available for filing. The 2011 Form M-1 is generally the same as the 2010 version, but with some minor changes for laws that became effective in 2011. The 2011 Form M-1 is due March 1, 2012, with an available extension until May 1, 2012. In addition, the DOL recently announced significant proposed changes to the Form M-1. Most notably, the proposed Form
M-1 incorporates changes imposed by the Patient Protection and Affordable Care Act, which requires MEWAs to register with the DOL and file at least 30 days prior to operating in a state or expanding their operations in an additional state, and within 30 days of a merger, material change or a participant contribution increase of 50 percent or more. The proposed Form M-1 also requires the provision of more extensive custodial and financial information. The DOL is seeking comments on the proposed Form M-1 until March 5, 2012. A copy of the 2011 Form M-1 can be found here. A copy of the proposed Form M-1 and its proposed instructions can be found here.

The lawyers of our Employee Benefits and Executive Compensation Practice Group are readily able to assist companies on a nationwide basis with implementing sophisticated benefit plans and providing answers to their most challenging compensation issues. Additionally, our lawyers are well aware of the daily employee benefits challenges facing companies of all sizes and are capable of helping in-house lawyers and human resources personnel with the day-to-day advice and guidance necessary to properly administer employee benefits plans.

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January 2012