Your global headcount does not buy your US plan anything.
If your company is headquartered outside the United States and employs people inside it, a US carrier rates the US entity — its own employees, its own claims, its own state. The people your group employs everywhere else do not enter the calculation. That is usually the first surprise, and it is the smallest one.
We are an independent employee benefits consulting firm, licensed well beyond Michigan. We handle the United States piece for employers whose decisions get made somewhere else — the plan, the renewal, the compliance calendar and the day-to-day service — and we write the analysis so it survives translation to an approver who has never bought health insurance.
This is not an edge case here. Published figures put more than three hundred thousand Michigan jobs at internationally owned companies, most of them in manufacturing.
Send us your renewalSkip to what actually counts as your US headcount →
Almost nothing your parent company knows about health coverage applies here.
What is actually true about a US plan
- In most of the world, health coverage arrives through a statutory system funded by a payroll contribution. In the United States the employer buys it in a commercial market, and medical is usually the second largest line on the US budget after payroll itself. A budget built on the parent’s assumptions is almost always short.
- The carrier rates the US entity. Global revenue, global headcount and the parent’s credit rating buy nothing. A newly established US operation also has no claims history, so its first renewals are priced from census and manual rates and can feel arbitrary until there is experience to argue with.
- Obligations follow where the employee works, not where the payroll sits. State insurance rules, state leave laws, state continuation and federal reporting all attach to the US work location — and a parent-country benefits policy is not a plan document.
- Benefits are a hiring instrument here in a way they are not in most markets. A US candidate compares deductibles, networks and out-of-pocket maximums between two offers, so an under-specified plan costs you people rather than goodwill.
What CFH does about it
- Prices the US market every year against what employers your size actually received, and delivers it as a recommendation in language an approver abroad can act on — not as a file to interpret.
- Counts your US workforce the way the rules count it, across every US entity under the same ownership, so you learn you are an applicable large employer before the filing deadline tells you.
- Keeps the plan documents, the notices you owe employees and the filing calendar in one place, so the US entity can answer a question without calling head office.
- Works to your approval chain and your time zone, and starts early enough that renewing as-is is a decision somebody made rather than what happened because nobody had time.
The fifty-employee line is drawn around your US entities, not around your company.
Nearly every US obligation that matters turns on a headcount, and it is not the number on your global organization chart. Two rules decide it, and they pull in opposite directions.
Employees working only abroad are generally not taken into account when the fifty-employee threshold is measured; the count looks at work performed in the United States, and hours paid as income from sources outside the country are left out. A parent with thousands of people across Europe or Asia and thirty in Michigan is, for this purpose, an employer of thirty.
What we do about it: establish which of your people the count actually reaches, including anyone on a US payroll doing US work whom the parent does not think of as a US employee.
Businesses with a certain level of common or related ownership are generally treated as one employer for the threshold. Three US subsidiaries of thirty, forty-five and twelve are not three small employers — they are one employer of eighty-seven, subject to the mandate and to the annual reporting that comes with it. Each entity then carries the obligation in its own name, so nobody gets to file on behalf of the group.
What we do about it: run the aggregation across your US entities once, then say plainly which entity owes which filing and when.
The threshold is measured on the prior calendar year. So the year you acquire a second US business, or staff up a new plant, is the year you are still not an applicable large employer. The following year you are — and the reporting covers a year in which nobody was collecting the data for it.
What we do about it: run the look-back against your own hiring plan rather than the calendar, so the year you cross is known in advance instead of discovered afterwards.
Cafeteria-plan and self-funded-plan nondiscrimination testing looks at the related group, not the single entity. At a US subsidiary that bites harder than it does elsewhere, because the highly compensated group is often a large and well-defined share of a small payroll. Plan documents, participant disclosures and annual filing obligations attach to the plan the US employer maintains, wherever the company is incorporated.
What we do about it: treat the governance as part of the plan rather than paperwork after it — documented process, tests run on time, and a file that answers an auditor.
Your US number decides which conversation this is.
The parent’s size sets the expectations. The US number sets the rules, the funding options and the price.
2–50 employees
Most first US operations sit here. You are community rated, so the renewal moves with who joined and left rather than with anyone’s claims, and the employer mandate has not reached you. Federal continuation obligations begin at twenty employees, which catches parents who assume nothing at all applies below fifty.
51–249 employees
The crossover. Your rate stops being a filed table and becomes your own experience, which is the first year in which negotiating has any room in it. It is also the first year the annual employee reporting is due, measured on a year that has already closed.
250–999 employees
Level funding and self-funding become real options, and for a US subsidiary they are often the first time the parent sees a number it recognizes — claims paid plus a fee, rather than a premium set in a market it does not follow. That is also the point at which the tests above start to matter.
1,000+ employees
Several US sites, often several legal entities, and a benefits stack that has to reconcile into one consolidated report for a fiscal year that may not be the plan year. The question stops being the rate and becomes the program.
The three questions a US operation asks us first.
Our parent already has a global benefits policy. Does it cover the US?
It will set intent — a minimum standard, a contribution philosophy, a wellbeing commitment — and almost none of it maps onto a US plan design, because the things a US plan is judged on do not exist in the systems the policy was written against. We translate the intent into a US design and show the parent what each level of it costs.
If something is filed late, who is actually responsible?
The US entity. Federal reporting and the plan documents attach to the plan the US employer maintains, whoever owns that employer, and each related entity carries its own filing in its own name. Worth settling before an audit rather than during one.
We have twenty people here. Is a consultant worth it?
At twenty people the plan is simple and the obligations around it are not — federal continuation begins at twenty employees, and the notices you owe a new hire begin at one. For proper coverage of an account we work in service teams of five, so a twenty-life US operation gets the same five named people as a two-thousand-life one.
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.
Bloomfield Hills, MI 48304
248.370.8853
Colorado Springs, CO 80921
719.425.2649
Houston, TX 77084
281.404.5670