Seasonal layoffs break continuous coverage. That is a plan design question.
General contractors, trades and specialty subcontractors. Michigan winters interrupt the workforce, and the benefits program has to survive the interruption without restarting everyone’s eligibility.
Written for a workforce that stops in January and starts again in April.
What Is Actually True in Construction
- A seasonal layoff can force returning employees back through a waiting period unless the plan’s rehire and eligibility language is written for it.
- On prevailing-wage work the benefits contribution can count toward the fringe obligation, which changes the economics of offering a richer plan.
- If part of the workforce is covered by a multiemployer trust, you are running two populations and only control one of them.
- Crews move between jobsites and states, so enrollment and network adequacy are both mobile problems.
What CFH Does About It
- Writes eligibility and rehire language that survives a seasonal layoff.
- Structures the plan so the contribution works against the fringe obligation where prevailing wage applies.
- Keeps the non-bargained plan coherent alongside whatever the trust provides, and says which levers you do not control.
- Runs enrollment at the jobsite, on the shift.
Six Industries We Serve in Construction.
Each industry below has its own guide to eligibility, funding, compliance and retention for employers like yours.
General Contractor and Homebuilder
Benefits planning, eligibility rules and cost control for general contractor and homebuilder employers.
Plumbing HVAC and Electrical Contractor
Benefits planning, eligibility rules and cost control for plumbing hvac and electrical contractor employers.
Roofing Siding and Remodeling Contractor
Benefits planning, eligibility rules and cost control for roofing siding and remodeling contractor employers.
Excavation Paving and Heavy Civil Contractor
Benefits planning, eligibility rules and cost control for excavation paving and heavy civil contractor employers.
Concrete Masonry and Foundation Contractor
Benefits planning, eligibility rules and cost control for concrete masonry and foundation contractor employers.
Glass Flooring and Cabinet Shop
Benefits planning, eligibility rules and cost control for glass flooring and cabinet shop employers.
Four sizes, four different problems.
Find your headcount. What changes at that size in this industry, and what we do about it.
There is no employer mandate below fifty, but COBRA obligations begin at twenty employees and a seasonal workforce reaches that quickly.
What we do about it: Sets rehire and eligibility rules that hold through the winter, and prices the market annually.
Applicable-large-employer status is measured on the prior calendar year, so a busy season creates an obligation a year later, in a slower one.
What we do about it: Runs the look-back against your real seasonal pattern so the obligation is not a surprise.
Claims become credible, and a trades workforce’s claims concentrate in musculoskeletal injury and imaging.
What we do about it: Models funding on your own claims and targets the categories actually driving them.
Multiple regions, multiple jobsites and often a mix of bargained and non-bargained crews.
What we do about it: Runs one program across the regions and keeps the bargained and non-bargained sides clearly separated.
Construction employers we see, and what each one needs.
Utility Field Services and Line Contractor
Group health benefits for Michigan utility line contractors and field service firms: storm response, travel, and variable hours.
Solar and Energy Services Company
Group health insurance for Michigan solar installers and energy services companies: fast-growing teams, field crews, sales staff and small-group options.
Telecom, Cable and Broadband Contractor
Group health insurance for Michigan telecom, cable and broadband contractors: field technicians, installers, on-call schedules and fast-growing teams.
Marine Construction and Dredging Contractor
Employee benefits for Michigan marine construction and dredging contractors: crews that move between sites, seasonal hours, eligibility and cost.
ICHRA for Construction and Skilled Trades Employers
How construction and skilled trades employers can use an ICHRA: union and non-union classes, seasonal crews, job-site rating areas and affordability. Ask CFH.
The three things employers in this sector ask us first.
What happens to coverage during a winter layoff?
It depends on how your eligibility and rehire language is written. Done properly, returning crews do not restart a waiting period. The language that matters is how long a break can last before a returning employee is treated as new, and whether prior service is credited. Once you are an applicable large employer, the ACA’s own break-in-service rules also apply, so the plan should be written to match them.
Can our benefits contribution count toward the prevailing wage fringe?
On covered work, yes, where the plan is structured for it, which changes what a richer plan actually costs you. Whatever the plan contribution does not cover is paid as cash fringe, which carries payroll taxes. Credit for the contribution is generally figured on an hourly basis across all hours worked, so the plan and payroll records have to support the calculation.
We have union and non-union crews — can one broker handle both?
Yes for the plan you control. Where a multiemployer trust provides the bargained benefits we manage around it and tell you which levers are not yours. In practice that means eligibility rules that say clearly who is covered by the trust and who is on your plan, so no one is double covered or left without coverage when they move between jobs or crews.
Construction Benefits: The Detail
Federal rules are the same across industries. These are the workforce factors that shape benefits for this sector.
Project-Based Work
Crews move between jobs, so hours and headcount shift. When hours vary from week to week, it is harder to tell who is eligible for coverage and who counts as full-time. A consistent method for tracking hours, applied the same way to every crew member, helps keep eligibility decisions and employer cost predictable.
Union and Multi-Employer Plans
Some contractors contribute to collective bargaining plans. Employees covered by a union or multi-employer plan may work alongside employees on the company’s own plan, and the two groups follow different rules. Knowing who is covered where, and what contributions already provide, helps avoid gaps and duplicate coverage.
Seasonality
Weather affects hours and hiring. Winter slowdowns and busy summers mean headcount and hours rise and fall through the year. Planning for who stays eligible during slow periods, and how coverage works when someone is laid off, helps employers avoid surprises and keeps employees informed about their options.
Field and Office Staff
Different groups often need different eligibility classes. Office staff and field crews usually differ in schedules, pay structure and benefit needs. Separate eligibility classes can work when they are based on bona fide job categories and applied consistently, and an adviser should confirm the nondiscrimination rules before changes are made.
Common Questions for Construction Employers
Do union contributions satisfy our benefit obligations?
They may in part, and the ACA has rules for multiemployer plan contributions. Review your situation.
How do we handle seasonal layoffs?
Plan eligibility and COBRA rules determine coverage when hours fall or employment ends.
Can field and office staff have different plans?
Yes, by bona fide job class within nondiscrimination rules.
Do the federal benefit rules differ for construction 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.
Construction and Skilled Trades Employers
Benefits around seasonal work, crews that move and union agreements.
Electrical, Plumbing and HVAC Contractors
Benefits for trade contractors with jobsite crews.
General Contractors and Homebuilders
Benefits for contractors managing many trades.
Seasonal Layoffs and Benefits
Keeping coverage through the winter slowdown.
Landscaping and Snow Removal
Benefits for seasonal outdoor service companies.
Excavation, Paving and Heavy Civil
Benefits for seasonal crews and equipment operators.
Roofing, Siding and Remodeling
Benefits for storm-driven residential contractors.
Demolition and Environmental Remediation
Demolition, abatement and remediation crews work irregular project cycles with specialized training and medical surveillance schedules, which makes group benefits harder to keep consistent.
Utility and Pipeline Construction
Utility and pipeline contractors move crews across counties and sometimes states, so networks, travel and per diem all shape what a workable benefit plan looks like.
Glazing, Steel Erection and Ironwork
Ironworkers, glaziers and steel erectors do physically demanding, high-skill work where retention and a competitive package matter as much as the hourly rate.
Land Development and Subdivision
Land developers and subdivision builders run lean in-house teams that rise and fall with the market, and benefits have to work for a small core staff.
Pool, Fencing and Specialty Trade Contractors
Pool builders, fence installers and other specialty trades are small, seasonal and owner-run, so the benefit plan has to be simple and affordable to administer.
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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