Every property is a worksite, and none has an HR office.
Property management, leasing, rental and equipment services. The corporate office is small; the workforce is spread across buildings, sites and routes that were never designed to administer a benefits plan.
Separate entities on paper, one employer under the rules.
What Is Actually True in Real Estate and Leasing
- On-site staff — maintenance, leasing, grounds — are spread across properties, so the plan has to be administered without anyone being in one place.
- Portfolios change: an acquisition or a new management contract can move a group of employees onto your plan mid-year.
- Entities are often separate companies that may nonetheless be a single controlled group for benefits purposes, which changes who counts toward applicable-large-employer status.
- On-site roles are frequently part-time or seasonal, so eligibility is a measurement question rather than a job title.
What CFH Does About It
- Runs enrollment property by property rather than expecting people to come to a corporate office.
- Handles mid-year population changes from acquisitions without breaking the plan year.
- Tests the controlled-group question before the applicable-large-employer calculation depends on it.
- Documents variable-hour eligibility for on-site roles.
See how we work a whole benefits program →
Brokerages with 1099 agents: one group plan for agents and staff →
Six Industries We Serve in Real Estate and Rental and Leasing.
Each industry below has its own guide to eligibility, funding, compliance and retention for employers like yours.
Affordable Housing Property Management Company
Benefits planning, eligibility rules and cost control for affordable housing property management company employers.
Commercial Real Estate Owners and Developers
Benefits planning, eligibility rules and cost control for commercial real estate owners and developers employers.
Apartment Community and Self Storage Operators
Benefits planning, eligibility rules and cost control for apartment community and self storage operators employers.
Real Estate Brokerage and Title Company
Benefits planning, eligibility rules and cost control for real estate brokerage and title company employers.
Condominium and Homeowner Association Management Company
Benefits planning, eligibility rules and cost control for condominium and homeowner association management company employers.
Apartment and Residential Rental Operator
Benefits planning, eligibility rules and cost control for apartment and residential rental operator employers.
Four sizes, four different problems.
Find your headcount. What changes at that size in this industry, and what we do about it.
A small corporate office plus scattered site staff can add up to more full-time equivalents than anyone expects.
What we do about it: Runs the controlled-group and full-time-equivalent calculations properly, then prices the small-group market.
Applicable-large-employer status begins, and it is calculated across the controlled group, not per entity.
What we do about it: Establishes which entities aggregate and builds the reporting once, for the group.
A larger portfolio makes claims credible, but each acquisition changes the census mid-year.
What we do about it: Models funding that tolerates a moving census and handles mid-year additions cleanly.
Properties across many states mean many sets of state rules and a network map per market.
What we do about it: Maps the rules and the networks market by market and runs one program over the top.
The three things employers in this sector ask us first.
Our properties are separate companies — do they count together?
Possibly. The controlled-group and affiliated-service-group rules aggregate common ownership, and we establish that position before your applicable-large-employer calculation depends on it. Parent-subsidiary and brother-sister ownership can both combine companies, and family ownership can be attributed across entities. If they aggregate, every company’s full-time and equivalent employees are added together, although each company still makes its own offers and files its own forms.
How do we enroll staff who never come to the corporate office?
Property by property, on site, with materials a site manager can actually run. Site managers get a simple guide and the enrollment materials, and employees can call us directly for help choosing a plan rather than waiting for someone from the corporate office.
We just took on a new portfolio mid-year. What happens to the plan?
New employees enter under your existing eligibility rules. We handle the mid-year addition so the plan year and the reporting stay intact. Where the seller had its own plan, we check that coverage runs to the closing date so nobody falls into a gap, and whether the carrier will waive the waiting period for transferred staff.
Real Estate and Rental and Leasing Benefits: The Detail
Federal rules are the same across industries. These are the workforce factors that shape benefits for this sector.
Agents and Employees
Many agents are independent contractors, and classification matters. Worker classification drives who is eligible for the plan, so we confirm each role with your counsel or payroll adviser, set clear eligibility rules in the plan document, and keep enrollment records consistent for agents, staff and anyone in between.
Small Offices
Small groups face carrier participation rules. Carriers often expect a minimum number of enrolled employees and a minimum employer contribution, which can be hard for a small office to meet. We review those requirements early and structure contribution and waiver rules so the group stays eligible.
Commission Income
Variable pay affects affordability and enrollment. When pay swings from month to month, the cost of coverage can feel different each pay period and can affect affordability tests. We help you choose a contribution approach that stays workable when income varies, and we explain it clearly to staff.
Property Staff
Maintenance and leasing staff may be hourly with variable hours. Variable hours make it harder to know who counts as full time for eligibility and reporting. We help you set a consistent way to track hours, define measurement periods with your advisers, and explain the rules so maintenance and leasing staff know where they stand.
Common Questions for Real Estate and Rental and Leasing Employers
Are agents eligible for our plan?
Only if they are employees under the plan terms. Contractors generally are not.
How does commission pay affect coverage costs?
It affects affordability tests and enrollment decisions.
What do small real estate groups need to know?
Carrier participation and contribution rules apply. Confirm them first.
Do the federal benefit rules differ for real estate and rental and leasing employers?
The core federal rules, including ERISA, the ACA, COBRA, and HIPAA, apply the same way. Workforce shape is what differs.
How do we know if we are a large employer for the ACA?
By averaging full-time equivalent employees in the prior calendar year. Fifty or more makes you a large employer.
When does COBRA apply?
Generally when you have 20 or more employees.
How early should we start on a renewal?
Months before the effective date, so there is time to compare options.
What do you need to get started?
Your renewal, plan summaries, and a census.
Can you review our renewal?
Yes. Send it to us.
Related guides.
Real Estate and Property Management
Benefits for agents, office staff and on-site teams.
Apartment and Residential Rental Operator
Apartment operators employ leasing agents, property managers, and maintenance technicians across communities that never close.
Equipment and Vehicle Rental and Leasing Company
Rental and leasing companies run counters, yards, and fleets.
Condominium and Homeowner Association Management Company
Community management firms run associations, handle budgets and vendors, and answer to boards and residents.
Employee
Real estate brokerages run on agents who are usually independent contractors, supported by a smaller team of employees.
Commercial Real Estate Owners and Developers
Commercial owners and developers often hold each building in its own entity.
ICHRA for Real Estate and Property Management Firms
An individual coverage HRA lets a firm set separate allowances for salaried managers and office staff, hourly on-site and maintenance…
Manufactured Housing Communities
Manufactured housing community operators run small on-site teams of managers and maintenance staff spread across several properties.
Senior Housing Operators
Senior living operators are real estate and care employers at once, with caregivers, dining and maintenance teams on round-the-clock schedules.
Parking Facility Operators
Parking operators staff garages and lots with attendants, valets and managers on shift schedules, often with high turnover.
Guides for specific kinds of employers.
Commercial Real Estate Owners and Developers Employee Benefits in Michigan
How single-asset LLCs, management companies and development entities are counted together for the ACA employer mandate, and what that means for benefit planning in Michigan.
Apartment Community and Self-Storage Operators Employee Benefits in Michigan
Onsite lodging for resident managers, small site teams and Michigan earned sick time: the benefit rules that shape apartment community and self-storage employers.
Real Estate Appraisal and Inspection Firms Employee Benefits in Michigan
How worker classification for field appraisers and inspectors affects benefit eligibility and the ACA employer mandate count for Michigan firms.
Vacation Rental and Short-Term Rental Operators Employee Benefits in Michigan
How seasonal staffing at Michigan vacation rental operators interacts with the ACA seasonal employee definition, initial measurement periods and the Michigan Earned Sick Time Act.
Auto and Truck Rental and Leasing Companies Employee Benefits in Michigan
Hours of service, branch-by-branch measurement periods and monthly full-time tests for counter agents, shuttle drivers and lot staff at Michigan rental and leasing companies.
Where the Rules Come From.
The laws and rules named on this page link to the statute or regulation they come from. This is general information, not legal or tax advice, and rules change, so check the current text.
ERISA (29 U.S.C. Chapter 18)
The federal law that sets reporting, disclosure and fiduciary rules for employer-sponsored benefit plans.
COBRA Continuation Coverage (29 U.S.C. 1161)
Requires many group health plans to offer temporary continuation coverage after a qualifying event.
Affordable Care Act (Public Law 111-148)
The 2010 health reform law, with later amendments, behind employer coverage, reporting and market rules.
HIPAA Privacy Rule (45 CFR Part 164)
Federal privacy and security standards for protected health information held by health plans.
Send us your renewal.
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.
An independent employee benefits consulting firm. We look at the entire benefits program — cost, plan performance, risk and administration.
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