Mark Twain famously quipped upon receiving an erroneous report that he had died, “The report of my death was an exaggeration.” Today we could say the same of multiple employer plans.
Multiple employer plans (MEPs) were all the rage for the past few years, until the DOL released Advisory Opinion 2012-04A, in which it clarified its stance that “open” MEPs (those open to any adopting employer rather than closed to a select group of employers) are not single plans under ERISA but are a collection of single plans for each adopting employer. Read full article…