ERISA

MEP Proposed Rulemaking 

    • On December 21, 2018, CRI submitted comments to the U.S. Department of Labor regarding this proposed rule. Click hereto view the letter. All public comments can be viewed here.
    • Department of Labor Proposes Multiple Employer Plan Expansion (Groom Law Group, October 2018). The U.S. Department of Labor proposed rules that clarify which organizations can sponsor MEPs as defined by ERISA section 3(5). The impact on state-run MEPs is unclear, as the proposed rules do not explicitly mention them.
    • Court Ruling on Association Health Plans Leaves Future of DOL MEP Rule in Doubt (Groom Law Group, April 2019). The District Court of Washington, D.C. ruled that portions of the U.S. Department of Labor’s rule relating to the definition of employer related to Associated Health Plan undercut the Affordable Care Act. Because the definition of employer for MEPs under ERISA is similar to that of employer for Associated Health Plans, there is concern that a court may similarly block U.S. Department of Labor’s s new MEP rule.

ERISA Basics

View Recent DOL ERISA Advisory Council Reports:

CRI Policy Reports

  • Multiple Employer Plans: An Overview of Legal, Regulatory and Plan Design Considerations for States. Click here to learn more about how ERISA and other laws apply to MEPs.
  • Review of Potential Public Retirement Plan Options for Private Sector Employees/Employers in the State of Vermont. Click here to learn more about how ERISA and other laws apply to retirement plan design options.
  • State Initiatives to Expand the Availability and Effectiveness of Private Sector Retirement Plans: How Federal Laws Apply to Plan Design Options. Click here to learn more.

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