Your season decides who is eligible.
Country clubs and golf courses, fitness and recreation, arts organizations, venues and attractions. A year-round core staff runs alongside a seasonal workforce several times its size, and the plan has to tell them apart correctly.
The seasonal exclusion is real. It is also narrower than most people assume.
What is actually true in clubs, recreation and the arts
- Seasonal employees can be excluded from the full-time-equivalent calculation under the seasonal worker rules, but only where the position genuinely meets the definition and the plan is written to match.
- A small year-round core means one high-cost claimant dominates the renewal, with nothing to spread it across.
- Food and beverage staff are often tipped, which changes how the affordability safe harbors behave.
- Clubs and member organizations answer to a board or a membership, so the renewal decision needs the same paper trail as any other board decision.
What CFH Does About It
- Applies the seasonal worker and seasonal employee rules correctly rather than assuming every summer hire is excluded.
- Explains what actually drove a renewal when one claimant moved it.
- Chooses and documents the affordability safe harbor that fits tipped pay.
- Brings a documented renewal the board or committee can read.
Four sizes, four different problems.
Find your headcount. What changes at that size in this industry, and what we do about it.
The year-round core is small, but the seasonal count can push the full-time-equivalent calculation somewhere nobody expects.
What we do about it: Runs the full-time-equivalent and seasonal-worker calculations properly before the mandate question arises.
Applicable-large-employer status begins, and the seasonal exclusion is exactly where organizations this size get the reporting wrong.
What we do about it: Documents which positions are genuinely seasonal and builds the filing data around it.
Several venues or properties make claims credible, and the year-round and seasonal populations behave very differently.
What we do about it: Models funding on your own claims and separates the two populations in the analysis.
Multiple sites and a large seasonal operation mean several worksites and several state rule sets.
What we do about it: Runs one program across the sites and maps the rules that follow each.
The three things employers in this sector ask us first.
Are our summer staff exempt from the employer mandate?
Only where the positions genuinely meet the seasonal worker definition and the plan is written to match. It is narrower than most clubs assume.
One claim moved our renewal. What can we do about it?
First establish that this is what happened. Then the realistic options are funding, pooling level and marketing the case properly — and we will tell you which of those applies to you.
What should we be able to show the board about how the plan was renewed?
What was marketed, what came back, what was chosen and why — the same record you keep for every other decision of this size.
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.
Bloomfield Hills, MI 48304
248.370.8853
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719.425.2649
Houston, TX 77084
281.404.5670