Several companies, one controlled group — and the reporting follows the group.
Holding companies, management companies and family offices sit above operating businesses that may look entirely separate. For benefits purposes they frequently are not, and the consequences run in one direction: obligations aggregate.
Determined at the group. Filed at the entity.
What Is Actually True in a Multi-Entity Group
- Controlled-group and affiliated-service-group rules aggregate employees across entities, so applicable-large-employer status is determined at the group level even when payrolls are separate.
- Reporting follows each employer identification number separately, so one aggregated determination can produce several filings.
- Entities often sit on different plan years, different carriers and different brokers, which makes the group’s total spend invisible to the people approving it.
- A non-discrimination problem in one entity’s self-funded plan does not stay inside that entity.
What CFH Does About It
- Establishes the controlled-group position before the applicable-large-employer determination rests on it.
- Maps every entity’s plan year, carrier and renewal date onto one calendar.
- Consolidates purchasing where it helps and keeps entities separate where it does not.
- Runs non-discrimination testing at the level the rules actually apply.
Six Industries We Serve in Management of Companies and Enterprises.
Each industry below has its own guide to eligibility, funding, compliance and retention for employers like yours.
Holding Companies and Parent Subsidiary Groups
Benefits planning, eligibility rules and cost control for holding companies and parent subsidiary groups employers.
Shared Services and Management Companies
Benefits planning, eligibility rules and cost control for shared services and management companies employers.
Corporate and Regional Headquarters
Benefits planning, eligibility rules and cost control for corporate and regional headquarters employers.
Family Office and Private Wealth Staff
Benefits planning, eligibility rules and cost control for family office and private wealth staff employers.
Controlled Group and Multi Entity Employer Benefits Rules for Michigan Companies
Benefits planning, eligibility rules and cost control for controlled group and multi entity employer benefits rules for michigan companies employers.
Private Equity Portfolio Company
Benefits planning, eligibility rules and cost control for private equity portfolio company employers.
Four sizes, four different problems.
Find your headcount. What changes at that size in this industry, and what we do about it.
Two small operating companies can be an applicable large employer together while neither is alone.
What we do about it: Determines the group first, then prices the market for the group rather than entity by entity.
The group is over the threshold, and the filing obligation lands on each entity separately.
What we do about it: Produces the reporting per employer identification number from one consolidated data set.
Combined claims are credible even where no single entity’s are, which is where consolidation starts to pay.
What we do about it: Models funding for the group and shows what each entity’s share actually is.
Several businesses, several states and several vendor stacks, usually with no single owner of the total.
What we do about it: Runs the group as one program with one calendar and one set of reporting.
The three things employers in this sector ask us first.
Do our companies count together for the employer mandate?
If common ownership meets the controlled-group test, yes. Status is determined at the group even though filings are made per employer identification number. The test looks at common ownership through parent-subsidiary chains and brother-sister groups, and ownership held by family members can be attributed across them. Once the group is an applicable large employer, each entity must offer coverage to its own full-time employees or carry its own penalty exposure.
Can we put all our entities on one plan, and should we?
Often you can. Whether you should depends on the claims and the wage mix, and we model it before consolidating. A single plan simplifies purchasing and can make combined claims credible, but it also means one entity’s high-cost claims raise the rate for the others. Where wage levels differ sharply, contribution classes by entity or role can keep the plan affordable for lower-paid staff within the rules.
Who is responsible for filing when the entities are separate?
Each employer identification number files its own returns. We build them from one consolidated data set so they agree with each other. Each entity reports only its own employees, but offers of coverage and full-time status have to be tracked consistently across the group, especially for people who move between entities or work for more than one. We can help you with the filing, including late filings.
Management of Companies and Enterprises Benefits: The Detail
Federal rules are the same across industries. These are the workforce factors that shape benefits for this sector.
Multiple Entities
Several companies may sit under one parent. Each entity may have its own payroll, locations and benefit history, so a plan that fits one company may not suit another. Mapping out which entities participate, and under what terms, is a useful first step.
Controlled-Group Rules
Related employers are combined for ACA and other thresholds. Whether separate companies are treated as one employer for these purposes can change compliance duties and plan eligibility. The rules are technical, so ask counsel and your tax adviser to review the structure.
Executive and Staff Mix
Different groups may need different benefit approaches. Executives and staff often value different things, and one design rarely suits both. Consider separate classes where the rules allow, and have counsel confirm any class structure meets nondiscrimination and other requirements. Review the approach each year with counsel.
Shared Services
Central HR may administer benefits for subsidiaries. When one team runs benefits for several entities, clear procedures help, including who handles enrollment, billing and employee questions for each company. Consistent records make renewals and audits much easier. Write the process down so it survives staff changes.
Common Questions for Management of Companies and Enterprises Employers
How do multiple entities affect compliance?
Controlled-group rules can combine entities for thresholds, while each entity has its own reporting.
Can all entities share one plan?
Often yes, with correct structure and documents.
How do executive benefits fit?
Nondiscrimination rules limit how benefits can favor highly compensated employees.
Do the federal benefit rules differ for management of companies and enterprises 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.
Guides for specific kinds of employers.
New Subsidiaries, Spin-Offs and First-Year ALE Status Employee Benefits in Michigan
How the employer mandate treats newly formed entities, predecessor and successor employers and the first-year April 1 transition rule when a Michigan company adds or separates an entity.
Holding Companies and Parent-Subsidiary Groups Employee Benefits in Michigan
How controlled group rules, plan sponsorship choices and multiple employer welfare arrangement risk apply to holding companies and parent-subsidiary groups in Michigan.
Practice Management Organizations (MSO and DSO) Employee Benefits in Michigan
How management services and dental service organizations are treated under the affiliated service group rules, and what that means for counting employees and sponsoring plans across practices.
Shared Services and Management Companies Employee Benefits in Michigan
How affiliated service group rules, the common-law employer standard and leased or shared employees affect benefits at Michigan management companies and shared services entities.
Corporate and Regional Headquarters Employee Benefits in Michigan
How a headquarters office and the entities around it are counted together for the employer mandate, and what the controlled group rules mean for Michigan headquarters teams.
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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