What does CFH Insurance Consultants actually do?

We are an independent employee benefits consulting firm. We advise employers on group health, dental, vision, life, disability and voluntary benefits - plan design, funding, carrier and renewal negotiation, compliance, and the benefits administration that runs underneath all of it. The work is continuous rather than annual: the renewal is where it becomes visible, but most of it happens in the months either side.

How long have you been in business?

CFH has been operating since 2007. The people here have been in insurance considerably longer than the firm has existed, which is a different claim and worth keeping separate - the firm's own track record starts in 2007. The firm’s incorporation date is a matter of public record with the State of Michigan, if you want to check it.

Where are you, and where do you work?

Our main office is at 41000 Woodward Avenue, Suite 350 East, Bloomfield Hills, Michigan, with additional offices in Colorado Springs and Houston. Michigan is the home market and where most of the work is, but our licensing follows clients beyond it, which matters when an employer's people are not all in one state.

Are you independent, or owned by a carrier or a national group?

Independent. No carrier owns us and no national brokerage sets what we recommend, which is the whole reason a recommendation from us is worth reading. It is a fair question to ask of anyone advising you on a plan, because the answer determines whether the advice can ever point away from a particular carrier.

What size employers do you work with?

From small groups through the mid-market, and the work looks genuinely different across that range - under fifty the levers are plan design, contributions and carrier; above it your own claims start driving the number and funding becomes a real decision. If you want the version specific to your size, the pages by company size lay out what changes at each band.

What industries do you work in?

A broad mix rather than one niche, with real concentration in a few - manufacturing, health care, professional services, mortgage lending and hospitality among them. Industry matters less than workforce shape: a business with variable-hour staff across several sites has more in common with another business like it than with a competitor in its own sector.

Are you licensed outside Michigan?

Yes. Licensing follows the client rather than the office, which is what allows an employer headquartered here to be served properly when its people are spread across several states. If you have employees somewhere specific, ask us about that state directly - it is a factual question with a factual answer.

What happens in a first conversation?

Twenty to thirty minutes, no proposal. You describe what you have and what the renewal looks like, and we tell you whether the number is in line with what comparable employers are being quoted or whether it is not. If it is fair, we say so. Nothing is sent afterwards unless you ask for it. If you are comparing firms first, how to choose an employee benefits broker in Michigan lists the questions to ask each one.

Do we have to be a client to ask you something?

No. A large part of what we do before anyone signs anything is answering questions from employers who are working something out - a compliance date, a renewal that does not read right, whether an arrangement someone is pitching them is real. If it takes a few minutes, it takes a few minutes.

We are not a third-party administrator. We find, vet and manage the administrators our clients use, which means the administrator answers to somebody on your side of the table rather than to itself. We are licensed insurance brokers, not attorneys or accountants - though CPAs and ERISA attorneys are available to clients through the firm for the questions that need them.

Corporate Healthcare Compliance Guide 2026

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8 min read

Corporate Healthcare Compliance for Michigan Employers: ACA, ERISA and Reporting

The short answer: which rules apply to your Michigan business depends mostly on headcount. Any employer with a group health plan owes an ERISA summary plan description. At 20 employees COBRA applies. At 50 full-time equivalents the ACA employer mandate and its IRS reporting begin, and at 100 plan participants the Form 5500 is due. This guide walks through each layer, the 2026 numbers, and the calendar.

For how funding choices change your obligations, see our approach to health cost strategy and our overview of group health plans for Michigan employers.

Which Rules Apply at Which Size

Headcount	What it triggers
1 covered employee	ERISA applies to the plan, including the summary plan description (SPD)
20 employees	COBRA continuation coverage
50 employees	ACA employer mandate and IRS reporting (full-time equivalents); FMLA (50 employees within 75 miles, a separate count)
100 plan participants	Form 5500 annual filing (the exemption below 100 covers the filing only, not the SPD)

An employer can sit below the ACA threshold and still owe most of this list. Use our large employer FTE calculator to see where you land.

The ACA Employer Mandate

An applicable large employer (ALE) is one with an average of 50 or more full-time employees, counting full-time equivalents, in the prior calendar year. An ALE must offer coverage to at least 95% of its full-time employees (30 or more hours a week) and their children to avoid a penalty. The coverage must also be affordable and provide minimum value. The IRS explains the rules in its employer shared responsibility provisions and its questions and answers.

Affordability. For plan years beginning in 2026, the employee’s share of the lowest-cost self-only plan that meets minimum value cannot exceed 9.96% of income, tested through a safe harbor such as W-2 Box 1 wages, rate of pay or the federal poverty line. The figure is 10.22% for 2027 (Rev. Proc. 2026-26). See our affordability percentage guide.
Penalty A (4980H(a)). If you do not offer coverage to enough full-time employees and at least one receives a premium tax credit, the 2026 assessment is $3,340 per full-time employee, after the first 30.
Penalty B (4980H(b)). If coverage is offered but unaffordable or lacks minimum value, the 2026 amount is $5,010 for each employee who receives a premium tax credit. Penalty B is capped by the Penalty A amount.

These dollar amounts are indexed and rise every year, so confirm the current figures before you budget.

ACA Reporting: Forms 1094-C and 1095-C

ALEs report the coverage they offered on Form 1095-C for each full-time employee and transmit it to the IRS with Form 1094-C. Filing is due February 28 on paper or March 31 electronically (moving to the next business day when the date falls on a weekend). Electronic filing is required once you file 10 or more information returns of any kind in a year, and W-2s and 1099s count toward the ten.

You no longer have to mail a 1095-C to every employee. Instead, you can post a clear and conspicuous notice by March 2 that employees may request a copy, keep it up through October 15, and furnish a requested form within 30 days (or by January 31 if later). Late or incorrect filings carry information return penalties of up to $340 per return, and the same amount can apply separately to the employee statement.

ERISA, Plan Documents and Form 5500

ERISA requires a written plan document and an SPD that describes the plan in plain language. A carrier certificate or an enrollment guide is not an SPD, which is why many employers use a wrap document. Plans with 100 or more participants at the start of the plan year file a Form 5500 annually, due the last day of the seventh month after the plan year ends, with an extension available. Participants include covered employees plus COBRA participants and covered retirees, but not dependents. Plans with fewer than 100 participants that are fully insured, unfunded or a combination are exempt from filing, but not from the SPD. If you offer pre-tax premiums, you also need a written Section 125 cafeteria plan document.

Other Annual Notices and Attestations

Medicare Part D creditable coverage notice: to Medicare-eligible individuals before October 15 each year, with an online disclosure to CMS within 60 days of the start of the plan year. Your carrier or an actuary determines whether the plan is creditable.
Gag clause attestation: due December 31 each year for both fully insured and self-funded plans. On a fully insured plan, confirm whether the carrier files it for you rather than assuming.
COBRA notices for plans that are subject to them, and the SPD distribution described above.

Annual Compliance Calendar

When	What
By January 31	Furnish Forms 1095-C to employees if you are mailing them
February 28 / March 31	File Forms 1094-C and 1095-C with the IRS (paper / electronic)
By March 2	Post the 1095-C availability notice if you use the alternative method (keep it up through October 15)
60 days into plan year	Part D disclosure to CMS
Last day of the 7th month after plan year	Form 5500 (calendar-year plans: July 31, extension available)
Before October 15	Part D creditable coverage notice to Medicare-eligible individuals
December 31	Gag clause attestation

Our templates and checklists include ready-to-use versions, and the companion piece Healthcare Compliance for Employers in Michigan covers the regulations in more detail.

The Michigan Layer

Fully insured plans sold in Michigan are regulated by the Department of Insurance and Financial Services (DIFS) and must include state-mandated benefits. Self-funded plans governed by ERISA are generally outside state insurance mandates and premium tax, but not federal law, which is one reason funding choice affects your compliance workload. See our comparison of self-funded and fully funded plans.

Have a Renewal Coming Up?

Send us your renewal and we will tell you whether the increase is competitive. We review it at no cost, and you only need four documents.

Send Us Your Renewal

ICHRA and QSEHRA

If you reimburse employees for individual coverage instead of sponsoring a group plan, ICHRA and QSEHRA rules apply, including notice requirements, affordability testing for ALEs using an ICHRA, and reimbursement substantiation. Our ICHRA and QSEHRA guide covers the details. Dental, vision and disability benefits add their own rules; see our group dental buyer’s guide and, for retirees, group retiree medical benefits.

Frequently Asked Questions About Healthcare Compliance for Michigan Employers

What counts as an applicable large employer in Michigan?

An applicable large employer is one with an average of 50 or more full-time employees, including full-time equivalents, during the prior calendar year. Full-time means 30 or more hours a week. The test is federal and is the same in Michigan as everywhere else.

What are the ACA employer penalties for 2026?

For 2026 the Section 4980H(a) amount is $3,340 per full-time employee (after the first 30) when an employer fails to offer coverage and at least one employee receives a premium tax credit. The Section 4980H(b) amount is $5,010 per employee receiving a credit when coverage is unaffordable or lacks minimum value.

What are the ACA reporting deadlines?

Forms 1094-C and 1095-C are filed with the IRS by February 28 on paper or March 31 electronically. Employers can furnish 1095-C forms on request instead of mailing them to everyone by posting a notice by March 2, keeping it up through October 15, and furnishing a requested form within 30 days.

What is the ACA affordability percentage?

For plan years beginning in 2026 it is 9.96%, and for 2027 it is 10.22%. The employee cost of the lowest-priced self-only plan that provides minimum value cannot exceed that share of income, as measured through an IRS safe harbor.

Does a self-funded plan have to follow Michigan insurance mandates?

Generally no. Self-funded ERISA plans are outside state insurance mandates and premium tax, but ERISA and federal law including the ACA still apply. Fully insured plans must follow Michigan mandates under DIFS oversight.

Ensure Your Michigan Business Stays Compliant

Compliance is easier when someone owns the calendar. Schedule a compliance review or send us your plan documents and we will tell you which of these rules apply to your group and what is missing.

Unhappy with your current broker? Switch to CFH. Your employees won’t notice. You will.

Employee Benefits Overview Michigan Employers: ACA Compliance, Healthcare Mandates, Level-Funded Plans, and Employee Retention Strategies

An overview of employee benefits for Michigan employers: medical, ancillary, retirement and the compliance duties attached to each.

Read the Guide

Corporate Healthcare Compliance for Michigan Employers