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Multiple Employer Welfare Arrangements (“MEWA”) are required to file a statement titled “Management’s Discussion and Analysis” within ninety (90) days of the end of the MEWA’s fiscal year. This statement is primarily a narrative document setting forth information that enables regulators to enhance their understanding of the MEWA’s financial position, results of operations, changes in capital and surplus accounts and cash flow.
Generally, the discussion shall be of the two year period covered by the financial statements audited by a certified public accountant and shall use year-to-year comparisons or any other formats that, in the MEWA’s judgment, enhance the regulator’s understanding of its financial condition.
Where the financial statements reveal material changes from year to year in one or more significant line items, describe the causes for the changes to the extent necessary to provide an understanding of the MEWA’s business or operations. Incorporate reference to the exhibits or schedules of the financial statement where deemed appropriate. If the causes for a change in one line item also relate to other line items, no repetition is required on a line-by-line analysis of the financial statements. The discussion shall not merely repeat numerical data contained in the financial statements and schedules or exhibits to the annual statements.
The discussion and analysis shall also focus specifically on material events known to management that would cause reported financial information not to be necessarily indicative of future operating results or of future financial position. This would include descriptions and amounts of: (i) matters that would have an impact on future operations and have not had an impact in the past, and (ii) matters that have had an impact on reported operations and are not expected to have an impact upon future operations.
The discussion and analysis shall be of the financial statements and should provide regulators with information that is relevant to an assessment of solvency, financial position, results of operations, cash flow, and trends in the amount of capital and surplus.
MEWAs are encouraged to supply forward-looking information concerning trends, demands, commitments or events that: (i) are likely to occur, and (ii) are likely to have a material impact upon the company.