Governmental plans are not ERISA plans, and half the checklist does not apply.
Municipalities, townships, authorities, districts and public agencies. The compliance obligations you actually carry are a different set from the one a private employer carries, and advice written for private employers routinely gets this wrong in both directions.
Fewer rules than you are being sold. Not none.
What Is Actually True for a Governmental Plan
- Governmental plans are exempt from ERISA, so the plan document, summary plan description and Form 5500 machinery that drives private-sector compliance calendars does not apply in the same way.
- The obligations that do apply still bite: the employer mandate and 1095-C reporting, COBRA, Medicare secondary payer rules and the Part D creditable coverage disclosure.
- Plan changes are frequently a bargaining matter and a public one, with a meeting schedule and a record the renewal has to fit.
- Workforces are long-tenured, so the age curve, retiree coverage and the Medicare interaction are central rather than peripheral.
What CFH Does About It
- Applies the governmental-plan exemption correctly instead of running a private-sector checklist at you.
- Keeps the obligations that do apply on their own calendar, sourced to the agency that owns each one.
- Works the renewal to the meeting and bargaining calendar so a decision can actually be taken.
- Models the retiree and Medicare position alongside the active plan.
Four sizes, four different problems.
Find your headcount. What changes at that size in this industry, and what we do about it.
A small township or authority is community-rated, and an older workforce sits at the wrong end of the age band.
What we do about it: Prices the market annually and gets the Part D disclosure onto its own calendar.
The employer mandate and 1095-C reporting apply here the same as anywhere, even though ERISA does not.
What we do about it: Runs the obligations that apply and stops you paying for the ones that do not.
Self-funding becomes realistic, and a stable public workforce’s experience is an advantage in that analysis.
What we do about it: Models funding on your own claims and brings the decision in a form the board can adopt in public.
Several departments, bargained and non-bargained groups, and a retiree population alongside the active one.
What we do about it: Runs them as one program with one documented process and one calendar.
The three things employers in this sector ask us first.
Which federal requirements actually apply to a governmental plan?
The employer mandate and 1095-C reporting, COBRA, Medicare secondary payer rules and the Part D disclosure. ERISA’s plan document, summary plan description and Form 5500 requirements generally do not.
How do we handle retirees and Medicare-eligible employees who are still working?
With the Part D notice on its own calendar and the retiree position modeled alongside the active plan rather than separately.
Can a renewal be worked to fit our meeting and bargaining schedule?
Yes, and it has to be. We start early enough that a decision can be taken in public, on the record, at a scheduled meeting.
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
Colorado Springs, CO 80921
719.425.2649
Houston, TX 77084
281.404.5670