Several Companies Can Be One Employer for This Purpose
The threshold that decides whether you must offer coverage is not applied company by company. Where businesses share sufficient common ownership, they are aggregated and counted together. Three related entities of twenty people each are not three small employers below the line. They are one employer of sixty, above it.
The reason this hurts is timing. The count is taken across the prior calendar year, so by the time anyone works out that the group crossed the threshold, the obligation is already live and the reporting year is already underway. The penalty for not offering is assessed against the entity that employed the person, which means the arithmetic can arrive somewhere nobody was watching.
Work Worth Doing Before It Becomes Urgent
Map the Ownership Honestly
including entities held by family members, because the attribution rules reach further than most owners assume
Add the full-time equivalents across every related entity for the prior year
counting part-time hours in aggregate
Decide Which Entity Sponsors the Plan
Decide which entity sponsors the plan and whether all the others participate in it
Check whether the entities can even share one plan
which is usually simpler than running several
What Follows If You Are Over the Line
An Offer of Coverage to Full-Time Employees
tested for affordability against a federal standard rather than against what feels reasonable
Individual Statements to Those Employees At
Individual statements to those employees at the end of January
A filing to the federal government by the end of March electronically
mandatory in that form at ten or more returns in aggregate
A Carrier That Will Now Ask
A carrier that will now ask for the last three renewals and claims history as routine rather than as an exception
The Upside Nobody Mentions
Crossing the threshold is not purely a burden. Above it, your own claims experience begins to carry weight in how the renewal is built, which means good years can start working for you instead of disappearing into a book rate. Below the line that was never possible. It is worth understanding as a change in the game rather than only as a compliance cost.
Questions From Genesee County Family Businesses
We run three companies. Do we count them separately?
Almost certainly not, if the ownership overlaps sufficiently. This is the single most common misunderstanding we see in businesses of this shape.
Can all the entities be on one plan?
Usually, and it is generally the cleaner arrangement. The details depend on the ownership structure and are worth confirming rather than assuming.
A Mill Town Turned Flint Suburb
Flushing began as a mill town on the Flint River in the 1830s and grew into a residential suburb of Flint, with about 8,400 residents at the 2020 census and a Main Street historic district on the National Register. Most working residents commute into Flint and the wider Genesee County economy, so employers based in Flushing tend to be smaller: shops, restaurants, professional offices and family-owned firms, some of which run more than one related business.
Small Groups Need Clear Numbers
With a handful of employees, one renewal can change your budget. We show you what moved and what you can do about it.
Competing With Flint-Area Employers
Your employees can often find jobs in Flint with a large employer’s benefits package. A well-designed small group plan, or an ICHRA where it fits, helps you keep good people.
Networks Where Employees Live
Most Flushing families use Flint-area hospitals and physicians. We confirm those are in network before you switch carriers.
Bring Us the Structure and the Renewal
Bring us the renewal letter, the current plan summary, the contribution split by tier and the enrolled counts by tier — two more documents if you are at fifty or above — and we will tell you what the number is actually made of. Call 248.370.8853 or write to info@cfhic.com.
Start the Review Email info@cfhic.com Call 248.370.8853
An independent employee benefits consulting firm. We look at the entire benefits program — cost, plan performance, risk and administration.
Bloomfield Hills, MI 48304
248.370.8853
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Questions We Get
The questions employers ask us most are answered in full on our resources page.
