Multi-Employer Plans and Other Consideration Premium

[DF-T]

This question is in regards to Other Consideration Schedule T Premium and Multi-employer plans. We currently have a large multi-employer plan which to date consists of approximately 7,000 employers, mainly hospitals At this point, we are finding it administratively difficult to capture the individual participants from these 7,000 employers. For Schedule T reporting purposes, our question to you is, since this is a multi-employer plan, would it be appropriate to report the premium in: 1) the state of domicile of the multiemployer plan; 2) the state of domicile in which each plan employer resides; or 3) at the participant level (where each underlying member resides)?

Any guidance you can provide will be greatly appreciated.

[Lisa]

Below is the guidance from the annual statement instructions from both the life and health instructions.

Premium allocation ? Life and Annuity Insurance
Allocation methodology allowed is determined as follows:

• For individual policies, allocate and report premium and other considerations to the jurisdiction based on the residence of the policyholder, insured or payer
• For group policies not provided by an employer, allocate and report premium and other considerations to the jurisdiction based on the residence of each group member or the Rule of 500
• For group policies provided by an employer, allocate and report premium and other considerations to the jurisdiction based on the residence or employment location of each covered group member, or the Rule of 500

Rule of 500 - A group policy covering less than 500 members may allocate all group premium to the state or territory where the greatest number of members reside or are employed (for employer groups) or to the situs of the contract

Premium allocation ? Health Insurance
Allocation methodology allowed is determined as follows:

• For individual policies, allocate and report premium and other considerations to the jurisdiction based on the residence of the policyholder, insured or payer or on the situs of the contract
• For group policies not provided by an employer, allocate and report premium and other considerations to the jurisdiction based on the Rule of 500, or on the situs of the contract
• For group policies provided by an employer, allocate and report premium and other considerations to the jurisdiction based on the Rule of 500, location of employer or on the situs of the contract

Rule of 500 - A group policy covering less than 500 members may allocate all group premium to the state or territory where the greatest number of members reside or are employed (for employer groups) or to the situs of the contract

Thanks,
Lisa Mullen