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.