A union or employee association is an employer too. Its own staff need a group health plan, eligibility rules and a budget that hold up, separate from any member benefit fund it may help oversee.
How staff hours and part-time organizers set eligibility and mandate exposure.
How to set classes for business agents, clerical staff and officers without health-factor bias.
Income protection when an employee cannot work.
Confidential counseling for staff who handle member grievances and disputes.
Pre-tax premium payments that cut payroll tax for the hall and its staff.
What the plan must report and which employees must be tracked.
A union or employee association has its own staff, and those people need a group plan, a budget and clear eligibility, separate from any benefit fund the organization oversees for members. Mixing the two causes confusion about who pays, who is eligible and who the plan administrator is.
Write a clear policy for the staff plan: classes, waiting period, contributions and how elected officers are treated. Officers who are elected and not hired raise special questions about whether they are employees for plan purposes. Have the structure reviewed, and set up the compliance calendar like any other employer.
Answers for union officers, trustees and office managers.
Yes. A plan for the organization’s own employees is an ordinary employer group plan. A multiemployer fund for members is a separate arrangement with its own trustees, and the two should not be blended.
No. A tax-exempt organization that reaches the applicable large employer threshold has the same offer-of-coverage duties as any other employer, and a union hall or association with a sizable staff is no exception. Exemption affects income tax, not the ACA mandate. CFH counts employees correctly, tests whether the threshold applies, and explains the reporting that follows.
Yes. Some union or association staff, such as clerical employees or business agents, are themselves represented by a bargaining unit, and the agreement may set benefit terms. Plan changes should be checked against that agreement before anyone is told. CFH models options and prepares comparisons that work in negotiations, and counsel should review contract language before an announcement.
Eligibility turns on how the plan defines a covered class and on hours counted under the look-back method, where 30 hours a week or 130 hours a month marks full-time. A steward or officer who works a few hours a week may fall outside the class. Define it in writing so elected and appointed roles are treated consistently, and CFH can help draft it.
Sometimes. Classes must be based on bona fide job criteria, such as staff versus elected officers, and a self-insured plan faces added nondiscrimination rules that can limit favoring higher-paid people. Fully insured plans have lighter requirements. CFH reviews the proposed structure and its funding type before adoption, and counsel should confirm it works. That review protects both the organization and its elected leaders.
Reporting depends on organization size and funding and can include ACA forms, annual plan filings, summary documents and employee notices. A union with staff plans separate from member funds may have two sets of obligations. CFH builds a compliance calendar for each client, so deadlines such as open enrollment notices and filings are not missed.
Yes. A union local with a single W-2 employee who is not an officer can often sponsor a group plan, start it in any month and choose not to contribute. Carrier rules and funding type may vary by size. CFH explains what a small local or association can do and shows the plan options available in Michigan.
Send the renewal and plan documents for the staff plan. CFH compares the offer with other options for a group of your size and tells you whether it is competitive. We also point out the questions worth putting to the carrier, such as how claims experience and plan changes shaped the rates, before you sign.
Yes. Business agents, clerical staff and officers on payroll can call the CFH team during the enrollment window, and we talk through options that suit their families, including coverage tiers and out-of-pocket costs. Staff often spend time on the road or at meetings, so a call is easier than a long meeting. We explain choices in plain terms.
Send your renewal or call us. CFH starts with a review of the staff plan, who is eligible and what the organization pays, then reports what we see in plain terms. The first review costs nothing, and you are not asked to switch anything. Many unions begin by forwarding last year’s renewal and a current staff list.
No. The staff plan covers the organization’s own employees, while a member benefit fund is a separate plan with its own trustees, governing documents and rules. Mixing them can create compliance and fiduciary problems. CFH works on the staff plan and keeps its design and filings separate, and fund trustees and counsel handle the member side.
It depends on whether they are employees under the plan’s rules. Some officers are paid a salary and treated as staff, while others receive a stipend for service and may not qualify. Define the class in the plan document and have counsel confirm the treatment. CFH helps draft the eligibility language so officers are handled consistently.
Ready? Upload your renewal, or talk it through with someone first. No cost, no obligation.
This is general information for labor unions and employee associations, not legal or tax advice. Questions about member funds, trustee duties or tax status go to your counsel and tax advisor, and we will work with them.
We’ll tell you whether it looks competitive, where we see opportunity, and the five questions we’d put to your carrier. No cost, and no obligation to move anything.
The renewal letter
Your current plan summary
Contribution split by tier
Enrolled counts by tier
Four documents, two more if your group is 50 or more. Nothing else; every extra one is a reason to postpone.
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