About the Report

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The U.S. Department of Labor (DOL) Employee Benefits Security Administration (EBSA) administers and enforces the reporting, disclosure, and fiduciary requirements of Title I of the Employee Retirement Income Security Act of 1974 (ERISA). Multiple Employer Welfare Arrangements (MEWAs) and certain Entities Claiming Exception (ECEs) must file the Form M-1 report annually. Form 5500 is an annual report that employee benefit plans must file to satisfy reporting requirements under Title I and Title IV of ERISA and under the Internal Revenue Code. DOL’s regulations require all employee benefit welfare plans that file the Form M-1 to also file the Form 5500, regardless of size or funding method. DOL contracted Summit Consulting (Summit) to conduct a descriptive analysis of attributes reported on both the Form M-1 and Form 5500 by the Form M-1 filing population.

In the report, researchers analyze the Form M-1 filing population from 2012 through 2016. This population consists of filings from administrators of MEWAs and certain ECEs. Researchers implemented a descriptive analysis to (1) examine how attributes reported on the Form M-1 filing have changed over the study period, (2) compare information reported by this population on Form M-1 and Form 5500, and (3) identify the insurance providers who serve MEWAs and ECEs.

In Section 2, researchers provide background information on Form M-1 and filing guidelines. In Section 3, they describe the data sources used. In Section 4, they share descriptive statistics of the filing population. In Section 5 they summarize findings.

Key Takeaways

• Many attributes of the Form M-1 filing population remained relatively constant over the filing period, including the size of the filing population (547 filers in 2016) and the high rate of self-reported compliance with ERISA Part 7 provisions (99%). The total number of reported participants covered by MEWAs and ECEs annually has climbed from 1.5 million in 2012 to over two million in 2016. The majority of MEWAs and ECEs (69.6% in 2016) report that they are fully-insured and most entities not fully-insured report purchasing stop-loss coverage (80% over the period of study).
• Researchers looked to identify the insurance providers serving this population and their prevalence across filers. As reported on the Form M-1 by name, Blue Cross Blue Shield covered the largest share of MEWAs and ECEs for those that were fully-insured (31% over the period of study). Similarly, Blue Cross Blue Shield is the most common stop-loss coverage provider among Form M-1 filings in the study period that are not fully-insured (12.7%). For the population of Form M-1 filers that also filed a Form 5500 Schedule A, the most common insurance providers as reported by name for health insurance (Blue Cross Blue Shield, 24.5%) and life insurance (Unum, 10.9%) were identified.

Citation

Brotsos, H., Langford, R., Urdapilleta, O., Wong, B. (2018). Summit Consulting. Analysis of Form M1 Data. Chief Evaluation Office, U.S. Department of Labor.

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The Department of Labor’s (DOL) Chief Evaluation Office (CEO) sponsors independent evaluations and research, primarily conducted by external, third-party contractors in accordance with the Department of Labor Evaluation Policy and CEO’s research development process.