Can a DSO Transaction Create an Overlooked Filing Requirement (with Tyler Hubert)
One Minute Matters Video Series
3.31.26
If you're working on a DSO transaction, there's a compliance issue that comes up more often than most people expect.
Affiliated Service Groups (ASGs) are common in DSO structures, and depending on how employee benefits are arranged, they can unintentionally create a Multiple Employer Welfare Arrangement (MEWA), triggering a DOL Form M-1 filing requirement most people don't see coming.
Until recently, there was no formal way to fix a missed filing. That just changed.
The DOL has expanded its Delinquent Filer Voluntary Compliance Program to cover Form M-1 filings, providing MEWAs with a clear, penalty-reduced path to get into compliance.
If you're in a DSO deal, this is worth a few minutes of your time.
For more information regarding Dykema's Employee Benefits Group, visit our practice page.
