The questions employers ask us most, answered in full.
Not thought leadership. The actual questions that come up in a renewal meeting, written out properly so you can read the answer before you need it.
Four things you can use today.
Two of these are deadlines you already own. One is how we run an account. One is what this year’s renewals actually look like.
The compliance calendar
Every federal deadline that attaches to a health plan, with the rule stated first and the date beside it — Form 5500 and the summary annual report, 1095-C furnishing and filing, Part D creditable coverage, PCORI, and the COBRA clocks.
Everything you owe employees
Which notices can ride along in the annual enrollment guide, and which are event-triggered and start a clock the day the event happens. The second kind is where employers get caught.
Datum
How an account is run here: the same five stages every year, from setting the datum through to carrying the year. It starts from the position that total premium is the wrong number.
This year’s trend baseline
Three lines instead of one — the national trend, what was actually filed in the market, and your own renewal history. A single benchmark number tells you very little about your own plan.
Some of this, we tell clients before they ask.
Eighteen short positions on questions that come up in nearly every renewal conversation — the analysis itself, not just a link to where to read more, grouped by the same five areas as the rest of the site.
Self-funded is not one thing, and the paperwork proves it.
Everyday language treats fully insured, level-funded, and self-funded as points on a single spectrum of risk. ERISA uses the word “funded” more narrowly, to mean whether plan assets sit in a trust. By that definition, a fully insured plan and a self-funded plan paid from general assets are both unfunded, which is why either one can qualify for the Form 5500 small-plan exemption while a trust-funded plan cannot.
Level funding sits in the middle and gets misclassified the most often. It is self-funded up to the attachment point, so PCORI fees are still owed by the employer and Section 105(h) nondiscrimination testing still applies, even though the monthly bill looks and feels like a premium. Employers who compare funding options purely on projected savings tend to discover the second set of obligations only when a testing failure or a fee notice arrives.
Reference-based pricing is a different negotiation, not a discount.
Private health plans paid hospitals an average of 254% of Medicare rates, per RAND’s most recent Hospital Price Transparency study (Round 5.1, December 2024, using 2022 data). A separate look at one national reference-based pricing program, covering roughly 300,000 lives (Health Affairs Scholar, July 2026), found inpatient claims priced at 122% of Medicare versus 240% for commercially priced claims in the same data — a real gap, though the authors are careful to call it descriptive of one program in one year, not causal proof for every employer.
That gap explains the appeal, but reference-based pricing changes who negotiates and when, moving cost containment from a rate an insurer set in advance to a per-claim conversation the member can be pulled into. We advise on reference-based pricing case by case, modeled against a client’s own claims, rather than placing or administering a program ourselves. Whether it fits depends on a group’s tolerance for that conversation, not just the size of the number in the analysis.
A renewal runs on two clocks, and only one of them is ours to control.
The carrier’s clock starts when a complete, accurate request goes in and ends whenever underwriting finishes; how long that takes depends on the carrier and the completeness of the data, not on anything a broker can speed up by asking twice. The second clock is ours: once proposals land, turnaround is next-day, not queued behind other work. Groups often blame the wrong clock for a renewal that felt slow.
An annual notice cannot satisfy an obligation that a hire date or a plan change already triggered.
Required employee notices split two ways: what can ride inside an annual enrollment guide, and what cannot because it is tied to an event or a fixed date instead of an enrollment window. The Marketplace notice is due within 14 days of a hire date. A Summary of Material Modifications for a benefit reduction is due within 60 days of the change, not at renewal. COBRA’s election notice runs on its own clock the moment a qualifying event occurs. None of the three waits for open enrollment.
We check every compliance date against the agency that owns it — the Department of Labor for ERISA disclosures, the IRS for tax-code items like Form 5500 timing, PCORI, and Section 125 testing, and CMS for Medicare Part D — rather than a broker blog or a vendor’s summary page. The obligations that catch employers are rarely the well-known ones; they are the ones that do not announce themselves on a calendar built around the renewal date.
See which notices are tied to enrollment, and which are not →
Continuation coverage is not the same guarantee in every state.
Federal COBRA applies to employers with 20 or more employees and gives departing employees the right to continue group coverage, at their own cost, for a defined period. Many employers assume a state-level backstop covers everyone else. Michigan does not have one: an employer under 20 employees here has zero continuation obligation, federal or state. The size of the employer, not the reason someone left, is what decides whether continuation coverage exists at all.
Coordinating an administrator, tracking the 60-day election window and the 45-day first-premium deadline, and knowing which of those actually apply in a given state is what continuation administration is, separate from just having a policy that allows for it.
An ICHRA moves the decision. It does not remove it.
A traditional group plan puts the employer in the position of choosing the network, the plan design, and the carrier on employees’ behalf. An ICHRA replaces that with a defined contribution the employee spends on an individual-market plan of their own choosing. The employer’s job does not go away; it changes, from selecting one plan for everyone to setting a contribution structure, communicating how individual-market shopping works, and meeting the ICHRA’s own notice requirement, due 90 days before the plan year starts.
Compliance does not average across states. It applies state by state, to wherever the employees are.
A benefits program headquartered in one state is not graded on that state’s rules for employees working somewhere else. Leave law, continuation requirements, and paid-sick-time mandates attach to the employee’s work location, so a multi-state employer is not running one compliance program with exceptions — it is running as many overlapping programs as it has states, each with its own accrual, notice, and eligibility rules that do not defer to each other.
Fiduciary duty follows the decision, not the title.
ERISA fiduciary status attaches to whoever exercises discretion over the plan or its assets — selecting a carrier, choosing a TPA, approving a plan design change — whether or not “fiduciary” appears anywhere in that person’s job description. An HR director who signs off on a renewal without documenting how the decision was reached has taken on fiduciary risk without necessarily knowing it. Governance is what turns that exposure into a defensible, documented process instead of an assumption.
Choosing a benefits platform usually makes a bigger decision by accident.
Benefits enrollment, HR information systems, and payroll increasingly ship as one bundled contract, so selecting an enrollment platform can quietly decide who holds employee records and runs payroll too. That is a larger decision than the one most employers think they are making, and it deserves its own evaluation instead of inheriting whatever the enrollment vendor happens to include.
We advise on HR information system and payroll system selection and implementation, not only the benefits-enrollment platform, so that decision gets made deliberately before a vendor contract is signed, not discovered after.
The platforms consolidating right now are chasing scale, not your specific census.
Health intelligence platforms — the dashboards that turn claims and eligibility data into utilization trends, disease-prevalence rates, and cost drivers — are consolidating quickly, and each acquisition adds more employers and more aggregate data behind the same interface. That is real progress in how much a platform can see across the market. It says nothing about how well it explains what is happening inside one specific group.
A benchmark built on millions of lives is useful for context, not for a decision. The question an employer actually needs answered is narrower: why did our claims move the way they did this year, and what should we do about it before the next renewal. That answer comes from someone who has looked at the census behind the dashboard, not from an aggregate view of employers who look nothing like this one.
A payroll integration connects the systems. It does not connect everything in them.
The benefits platform connects directly to a range of payroll and HR systems. Once that connection is set up, demographic changes sync between the two systems within about a minute, and new hires and terminations flow from payroll into the benefits platform automatically instead of being re-keyed by hand.
What does not sync is the part worth knowing before relying on it. Deduction amounts move from the benefits platform to payroll only at enrollment or when a cost actually changes; base compensation flows the other way and is not something the benefits platform can edit; and several deduction types — 401(k), commuter benefits, and domestic partner deductions among them — do not cross the integration at all, because most platforms cannot split a single deduction into a pre-tax portion and a post-tax portion. Those still have to be managed by hand. An integration that is technically live can still leave real gaps in a payroll register if nobody is watching for them.
The integration will tell payroll someone left. It will not tell it why.
None of the payroll integrations we have reviewed pass termination reason across the wire. A termination shows up in the benefits platform as a fact — an end date — but not a reason, and most platforms default it to a voluntary separation regardless of what actually happened.
That default matters because the actual reason is often exactly what determines what happens next: COBRA continuation rights, unemployment claims, and rehire eligibility can all turn on whether someone quit, was let go, or was laid off. Trusting the integration to carry that distinction means trusting a field it was never built to carry — it still has to be entered by hand, every time, in whichever system needs it.
The wrong FSA can quietly disqualify the HSA sitting next to it.
An HSA-eligible high-deductible plan and a general-purpose health FSA cannot be paired — enrolling in both makes an employee ineligible to contribute to the HSA at all, even if the FSA is barely used. Employers who add a general FSA option without checking it against an existing HSA-eligible plan can strip contribution eligibility from employees who never knew there was a conflict. A limited-purpose FSA, restricted to dental and vision, is the fix, but it has to be built that way from the start.
Processing a claim and fighting one are different jobs.
Most of what a carrier or TPA does with a claim is administration: apply the plan design, pay what is owed, move to the next one. Advocacy is what happens after that process produces the wrong answer — a denial that should not have been a denial, a bill that does not match the plan’s negotiated rate, a stop-loss reimbursement that has to be requested rather than assumed. An employer needs someone assigned to the second job, not just confidence that the first one is running.
Employees compare job offers on salary because nobody hands them the other number.
A benefits package has a real dollar value — premium contributions, paid leave, disability and life coverage among them — but almost none of it appears on a pay stub or an offer letter next to the salary figure. Employees end up comparing offers on the number they can see, which undervalues employers who are actually competitive once the full package is counted. A total compensation statement puts a number next to every piece of it, once a year, so the comparison an employee is already making gets made with the right information.
A PEO changes who is responsible for the benefits plan, not just who runs payroll.
Joining a professional employer organization is usually evaluated as a payroll and HR-administration decision. It is also a benefits decision: under the co-employment structure, the PEO becomes the plan sponsor, which changes whose plan document governs, whose renewal timeline you are on, and what happens to coverage if the relationship ends. Those consequences are worth pricing in before signing, not after.
A wellness program’s obligations depend on what it asks of employees, not its name.
A wellness disclosure requirement applies to health-contingent programs — the ones that reward or penalize an outcome, like a biometric target or a tobacco-free result — and does not apply to participation-only programs, where completing an activity is the entire requirement regardless of outcome. Two programs marketed the same way inside a benefits guide can sit on opposite sides of that line, and the difference decides what has to be disclosed and how.
The Part D notice has no size exemption. Every employer owes it, every year.
Most compliance obligations soften or disappear below some employee count. The Medicare Part D creditable coverage notice does not: any employer offering prescription drug coverage owes the annual notice to Medicare-eligible individuals before October 15, regardless of group size, plus a separate disclosure to CMS within 60 days of the plan year start. It is one of the few notices that catches small employers exactly as hard as large ones, which is also why it is one of the more commonly missed.
What you are actually paying for, and why it moved.
Self-funded vs. fully funded health plans
The decision that changes everything downstream — who carries the risk, who keeps the surplus, and at what size it starts to make sense.
Employee benefits optimization strategies
Where the recoverable cost usually hides, and which levers are worth pulling before you touch the plan design.
Whether your plan is competitive is a question with an answer.
Group benefits benchmarking: Michigan cost analysis
What comparable Michigan employers are paying, contributing and offering — the comparison that settles an argument in a board meeting.
Benchmarking to attract talent and control cost
Using benchmark data as a hiring argument rather than only as a cost check.
Three lines, not one — national, local, and yours
A renewal percentage on its own tells an employer nothing. It needs two reference lines above it before it can be read at all: what happened to employers nationally, and what happened in this state to this kind of plan. Only with those in place does the third line — the employer’s own number — mean anything.
Nationally, employer health costs were projected to rise nine to ten percent for 2026 before any change to plan design, and roughly six and a half to seven and a half percent after employers made those changes. The distance between those two figures is the most misquoted thing in this subject. The lower number already assumes the employer went and changed something; if nothing changes, the higher one applies.
Locally, Michigan requires fully insured small-group rates to be filed with the state, and publishes every carrier’s approved change. The statewide small-group average was approved at 11.1 percent for 2026 and is proposed at 9.6 percent for 2027. Two limits travel with those figures wherever they go: above fifty employees rates are not filed at all, and a self-funded plan has no filed rate because it is not buying one. The filed table covers fully insured groups under fifty — and even inside it, no single employer gets the published number. Michigan requires per-member rating and allows rates to vary only by area, age within a three-to-one band, and tobacco, so each group’s own renewal moves with its own census on top of the filed change. The smaller the group, the harder that average age swings on one hire or one departure.
The published statewide figure also blends two different products. Split by plan type, the 2027 filings land near eleven percent on the HMO side and near eight percent on the insurer side, against a blended headline of 9.6. Run the same split on 2026 and the gap all but disappears. So quoting the blended number at one specific employer can be close to two points wrong in either direction, and which direction it is wrong in changes from year to year.
A self-funded employer needs a different set of numbers again. Its cost is claims, administration and stop-loss, and those three move on three different clocks — stop-loss premium rose roughly fourteen to sixteen percent for 2026 depending on the deductible, because the deductible stays put while the claims sitting above it grow. An employer told the market is nine percent has been handed a figure that describes none of its three components.
One renewal cannot show a bent trend line. Establishing whether an employer’s own cost line is running below the market’s takes several consecutive renewals set against the trend for those same years. That is the analysis — and it is why the first thing we ask for is the last few renewals, not only the current one.
Bring us the last few renewals and we will draw all three lines →
The obligations that do not announce themselves.
ERISA compliance checklist for employers
Plan documents, summary plan descriptions, filings and disclosures — what is required, and what auditors actually ask for.
Employee benefits strategy consulting
How a benefits program gets planned across several years instead of re-argued every autumn.
How the relationship actually works.
What is a broker of record letter?
The one-page document that moves your account — what it does, what it does not do, and what it does not cost you.
Choosing an employee benefits broker
What separates a broker you hear from at renewal from one that works the account all year.
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
719.425.2649
281.404.5670
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.