Your plan does not ask where an employee was born.
Employees who came to the US to work are generally eligible for your group plan on the same terms as everyone else. Most of the problems come from eligibility rules, dependents and paperwork, not from the employee’s status.
A group plan turns on hours, job class and tenure. It does not turn on citizenship. The work is making sure your plan document says that, that enrollment actually reaches a new arrival who has never used US health insurance, and that dependents living outside the country are handled the way the carrier says they will be.
What is actually true for foreign-national employees
What Is Actually True
- Eligibility should be written around hours, class and waiting period. A rule that excludes people because of citizenship or immigration status creates discrimination risk.
- For employees on certain work visas, the employer generally has to offer benefits on the same basis as it does to US workers. Immigration counsel confirms what applies to each visa category.
- Employees count toward the employer mandate based on hours worked in the US, not on visa category or citizenship.
- Dependents who live abroad are handled by the carrier’s rules, and some carriers limit or exclude coverage for them, so it has to be checked before enrollment, not after a claim.
What CFH Does About It
- We read your eligibility language and flag anything that turns on status instead of hours and class.
- We check how each carrier treats dependents living outside the US before you promise anything.
- We plan enrollment for people new to the US system, in plain language and with a person to call.
- We handle the paperwork gaps, such as a Social Security number that has not been issued yet, so enrollment and reporting stay accurate.
Four sizes, four different problems.
Find your headcount. What changes at that size for foreign-national employees, and what we do about it.
A small group often hires a handful of people from abroad, so one enrollment mistake is a visible one.
What we do about it: Writes the eligibility language once, checks it against the carrier, and walks each new arrival through enrollment.
Crossing fifty makes you an applicable large employer, and the hours of employees who arrived mid-year have to be counted correctly.
What we do about it: Measures hours correctly from the first day and keeps the offer record clean for reporting.
Multiple visa categories, multiple locations and a steady stream of arrivals make enrollment a process, not a form.
What we do about it: Builds an onboarding path for new arrivals and a standing check on dependents and documentation.
Large, international teams mean consistent eligibility rules and reporting across sites, and a reliable way for new arrivals to understand the plan.
What we do about it: Standardizes the rules and the reporting across sites and tests them on real cases.
The three things employers ask us first.
Do employees on work visas count toward our headcount?
Yes. Employees count based on hours worked and employee status, not on visa category or citizenship.
Can we cover an employee’s spouse and children who live outside the US?
It depends on the carrier and the plan. Some restrict coverage for dependents who live abroad, so we check the plan language before enrollment and tell you what is and is not covered.
Does a new arrival without a Social Security number have to wait for coverage?
Not necessarily. We work out the enrollment and reporting steps with the carrier and your payroll provider so the delay does not become a coverage gap.
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. →
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