Compliance Is Federal.
The mandate, 1094-C and 1095-C reporting, ERISA, COBRA and Form 5500 apply by headcount and plan structure. No industry is exempt from the parts that bite.
Industry never appears in the test. What matters is how many employees you have, what kind of plan you sponsor and how it is funded. Two employers with the same answers carry the same obligations, whether they build engines or run clinics.
What Is Actually True About Compliance
What Is Actually True
- The employer mandate applies to employers with fifty or more full-time and full-time-equivalent employees, and it is measured on headcount, not on what the business does.
- Employers subject to the mandate report coverage to the IRS on Forms 1094-C and 1095-C, and penalty exposure rests on the underlying eligibility data.
- ERISA governs the plan itself: the plan document, the summary plan description and the required notices. A carrier certificate or a benefits guide does not stand in for them.
- COBRA and Form 5500 turn on the size and structure of the plan, and self-funded arrangements carry more disclosure duty than fully insured ones.
What CFH Does About It
- We map which obligations apply to you by size and plan structure, in writing.
- We keep the calendar of filings, notices and renewal-driven deadlines, with an owner against each one.
- We check that your documents match the plan you actually run.
- We bring in the attorneys and CPAs available to our clients when a question needs one.
Where the Obligations Bite
Four moments when the federal rules stop being background.
The employer mandate starts to apply when you reach fifty full-time equivalents, and the first year is the easiest to get wrong.
What we do about it: We measure you before you cross and plan the first reporting cycle.
Forms 1094-C and 1095-C depend on a clean record of who was offered what, month by month.
What we do about it: We help you build that record during the year, so the filing is a read-out and not a reconstruction.
A termination or a drop in hours can trigger a COBRA notice with a deadline that does not move.
What we do about it: We make sure the notice process is running and documented.
Many employers have a carrier certificate and a benefits guide and no ERISA plan document.
What we do about it: We find the gap and close it with a wrap document.
Questions We Hear From Employers in Every Industry
Does Our Industry Exempt Us From Any of This?
No. These rules attach to headcount and plan structure. Industry can change how hard the administration is, but not whether a rule applies.
Is a Benefits Guide Enough as Our Plan Document?
Usually not. A benefits guide explains the plan to employees. A plan document and a summary plan description are separate documents with their own purpose, and we check whether you have them.
Who Is Responsible if a Filing Is Missed?
The plan sponsor, which is you. That is why we keep the calendar and make sure every deadline has an owner, whether it is ours, yours or a vendor’s.
Compliance Is Federal: The Detail
The big compliance obligations come from federal law and apply across industries. These are the core ones.
ERISA Governs Most Employer Plans
Plan documents, summary plan descriptions, fiduciary duties, and Form 5500 flow from ERISA. ERISA’s reach depends on the plan and the employer, so confirm with counsel which parts apply to each benefit. A written plan document and a summary plan description are commonly expected, and fiduciary duties come with them.
The ACA Adds Employer Duties
Larger employers must offer coverage and report on Forms 1094-C and 1095-C. Employers should check each year whether they count as large for ACA purposes, since the count can change. If the rules apply, they must offer coverage that meets the standards, and the reporting forms are due on fixed dates.
COBRA Applies at 20 Employees
Employers with 20 or more employees generally must offer continuation coverage. Employers near the size line should confirm with counsel whether COBRA applies, because state continuation rules can add duties for smaller groups. When it applies, notices and election windows are strict, and the plan or administrator needs a clear process.
Notices Have Deadlines
Required notices go out on fixed schedules, from the summary of benefits to the Medicare Part D notice. Employers should keep a calendar of notices, who sends each one, and when it is due, and keep proof that notices were delivered. Some notices are tied to the plan year and others to specific events, so the schedule needs regular review.
Common Questions About Federal Compliance
Which laws apply to our plan?
Typically ERISA, the ACA, COBRA, HIPAA, and the Internal Revenue Code. State rules add to them.
Does industry change the rules?
Not the core federal ones.
What notices must we send?
These include the SBC, the Medicare Part D notice, the HIPAA privacy notice, and others. Our compliance page lists them.
Do we need a plan document?
Yes. A carrier certificate is not a plan document.
When is Form 5500 due?
July 31 for a calendar-year plan, unless extended.
Who is responsible for compliance?
The plan sponsor, normally the employer.
Can a broker handle it?
We help with calendars and guidance. The legal duty stays with the plan sponsor.
What happens if we miss something?
Penalties can apply. Many problems can be corrected, so act early.
How do we start?
Ask for our compliance review.
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.
Switch to CFH. Unhappy with your broker? Your employees won’t notice. You will. →
Cookies on This Site
We use cookies to keep the site working properly and to understand how it is used. You can decline anything that is not essential. See our Privacy Policy for the detail.
- Essential — needed for the site to load and for you to move around it. These cannot be switched off.
- Analytics — tell us which pages get read, so we know what is worth writing more of.
- Advertising — set by third parties such as ad and social platforms to measure and target campaigns.