Seasonal labor, and a plan year that does not match it.
Growers, nurseries, food production, forestry. The workforce arrives and leaves with the season, and much of the federal benefits machinery was written for employers whose headcount does not do that.
Two workforces that share a payroll and almost nothing else.
What Is Actually True in Agriculture and Forestry
- The seasonal worker rules allow genuinely seasonal positions to be excluded from the full-time-equivalent calculation, but the test is specific and has to be applied deliberately rather than assumed.
- Employees on seasonal work visas have their own coverage rules, which are not the same as the rules for domestic seasonal staff.
- The year-round core is small, so a single claimant can dominate a renewal.
- Enrollment has to happen on site, in the languages the crew speaks, and frequently in print.
What CFH Does About It
- Applies the seasonal worker and seasonal employee rules properly rather than assuming the answer in either direction.
- Sorts out which coverage obligations attach to visa-based seasonal labor and which do not.
- Explains a renewal driven by one claimant instead of presenting it as a market movement.
- Runs enrollment on site and in the right languages.
Six Industries We Serve in Agriculture, Forestry, Fishing and Hunting.
Each industry below has its own guide to eligibility, funding, compliance and retention for employers like yours.
Farm Equipment Dealer and Agricultural Services Company
Benefits planning, eligibility rules and cost control for farm equipment dealer and agricultural services company employers.
Farm Orchard and Produce Grower
Benefits planning, eligibility rules and cost control for farm orchard and produce grower employers.
Nursery Greenhouse and Garden Center
Benefits planning, eligibility rules and cost control for nursery greenhouse and garden center employers.
Cannabis
Benefits planning, eligibility rules and cost control for cannabis employers.
Agricultural Cooperatives and Grain Elevators
Benefits planning, eligibility rules and cost control for agricultural cooperatives and grain elevators employers.
Dairy and Livestock Farm
Benefits planning, eligibility rules and cost control for dairy and livestock farm employers.
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 usually well under fifty, but the seasonal count is what makes people uncertain whether the mandate applies at all.
What we do about it: Runs the seasonal worker calculation so the answer is documented rather than assumed.
If the seasonal exclusion does not apply, applicable-large-employer status and reporting begin — and the data lives in a seasonal payroll.
What we do about it: Builds the filing data from the payroll you actually run.
A larger operation has a credible claims history for its year-round staff even where the seasonal population is transient.
What we do about it: Models funding on the population that stays and prices the rest realistically.
Multiple operations, often across states, and two workforces that share almost nothing.
What we do about it: Runs one program with two clearly separated populations.
The three things employers in this sector ask us first.
Do our seasonal workers count toward the employer mandate?
The seasonal worker rules can exclude them from the full-time-equivalent calculation, but the test is specific and has to be documented rather than assumed. The exclusion only works if headcount exceeds the threshold for a limited part of the year and the excess is made up of seasonal workers, so peak-season payroll records are what prove it. Run it every year, because a longer season can change the answer.
What coverage do we owe visa-based seasonal staff?
It depends on the visa program and the length of employment. The rules are not the same as for domestic seasonal staff, and we sort out which apply before you offer or decline. The answer can also affect your ACA count, since visa-based workers on your payroll can matter for whether you are an applicable large employer. We document the reasoning so it holds up if a reporting question comes later.
How do we enroll a crew that does not use email?
On site, in print, in the languages the crew speaks, during the working day. We time sessions around breaks and shift changes, bring printed summaries and forms, and keep the explanation to what each worker is actually choosing. Completed forms should then be checked against payroll, so each election actually reaches the carrier.
Agriculture, Forestry, Fishing and Hunting Benefits: The Detail
Federal rules are the same across industries. These are the workforce factors that shape benefits for this sector.
Seasonal Workforce
Peak-season hiring raises ACA and eligibility questions. Peak-season hiring can move headcount up and down quickly, which affects who becomes eligible and how ACA rules apply. Decide in advance how seasonal and temporary workers are classified, how their hours are measured, and when an offer of coverage is required, and confirm the approach with your adviser or counsel.
Variable Hours
Weather and harvest timing make hours uneven. When work follows weather and harvest cycles, weekly hours swing widely. Pick a consistent measurement method, apply it to every employee in the group, and keep records of how each person was classified so you can support the decision if the plan or a regulator asks about it later.
Dispersed Locations
Rural operations affect network access. Employees in rural areas may live a long way from in-network providers. Review network access by county before choosing a plan, and weigh how well telehealth, mail-order prescriptions and urgent care options fill the gaps for staff who cannot easily reach a nearby doctor or hospital.
Family Ownership
Related entities may be combined for threshold purposes. Related companies owned by the same family may be treated as a single employer for some benefit thresholds, which can change which rules apply. Have your benefits adviser and counsel review how the entities are connected before you set eligibility, offer coverage or file required reports.
Common Questions for Agriculture, Forestry, Fishing and Hunting Employers
How do seasonal workers affect ACA status?
An employer whose workforce exceeds 50 for 120 days or fewer, with the excess seasonal, is not treated as a large employer. Facts matter, so review yours.
Do we need to offer coverage to seasonal workers?
Large employers must offer coverage to full-time employees, including seasonal workers who meet the full-time definition.
How do rural networks affect plan choice?
Check provider access where employees live before choosing a plan.
Do the federal benefit rules differ for agriculture, forestry, fishing and hunting 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.
Agriculture and Farm Employers
Benefits for seasonal, migrant and year-round workers.
Farms, Orchards, and Produce Growers
Benefits for harvest-driven hiring.
Greenhouses, Nurseries, and Agribusiness
Plans built around the growing calendar.
Family Farm Medical Reimbursement
Reimbursement plans for farm families.
Dairy and Livestock Farms
Benefits for year-round farm crews.
Forestry, Logging, and Sawmills
Benefits for remote crews.
Seasonal Harvest Labor
Eligibility for harvest workers.
Farm Equipment Dealers and Ag Services
Benefits for technicians and parts staff.
Hunting Outfitters and Guides
Hunting outfitters and guides work a short, intense season in rural areas, with owners and a few seasonal guides.
Vineyards and Winery Growers
Vineyard and winery growers run a labor-intensive harvest season on top of a small year-round team in northern Michigan wine country.
Guides for specific kinds of employers.
Commercial Fishing and Aquaculture Employee Benefits in Michigan
How seasonal crews, non-hourly pay and off-season gaps shape benefits for commercial fishing and aquaculture employers.
Agricultural Cooperative and Grain Elevator Employee Benefits in Michigan
How seasonal harvest crews, large-employer counting and hour records shape benefits for cooperatives and grain elevators.
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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