Your plan and the trust run on different calendars, and your employees move between them.
Employers in a multiemployer plan also sponsor benefits directly for office, management and other non-union roles. When someone moves between those roles, eligibility rules and plan years collide, and people end up covered twice or not at all. We structure the direct plan so it fits around the trust’s calendar.
The trust earns eligibility from past hours. Your plan grants it from a start date.
That difference creates the gaps and the overlaps, and each one has a fix that belongs in the plan document.
Promotion Out of the Unit
A foreman promoted into management may keep trust coverage for months from banked hours. If your plan also covers them from day one, you pay twice, so we tie the direct plan’s start to the end of trust coverage.
Moving Into the Unit
A worker moving into covered work may not earn trust eligibility until hours accumulate. If your plan ends on the transfer date there is a gap, which is why the direct plan needs a bridge rule.
Different Plan Years
The trust renews on its schedule and your plan on yours. We align enrollment and elections so a mid-year transfer does not strand a spouse’s coverage or a spending account election.
Waiting Periods
Your plan cannot apply a waiting period longer than 90 days, while multiemployer plans have their own accommodation for hours-based eligibility. We make sure the bridge rules satisfy both, so neither plan applies a wait it should not.
The employer mandate counts all your full-time employees, union and non-union alike.
Applicable large employer status and the offer-of-coverage rules look at the whole company. How trust coverage counts toward your offers follows specific IRS guidance.
Counting Everyone
Union and non-union full-time employees together decide whether you are an applicable large employer. A company that thinks of itself as small because most staff are in the trust may not be, which is why we run the count.
Trust Coverage and Your Offers
IRS guidance gives employers required to contribute to a multiemployer plan a specific way to treat trust coverage as an offer when its conditions are met. Counsel confirms it applies; we confirm the facts it depends on.
Reporting Both Populations
Forms 1095-C have to reflect union and non-union employees alike. We line up what the trust provides with what your plan knows, and we can help you with the filing.
The direct plan should be designed and tested for the people it actually covers.
Collectively bargained employees are treated differently under several federal rules, so the direct plan has to account for them.
Nondiscrimination Testing
Cafeteria plan and self-insured medical testing can treat collectively bargained employees differently from everyone else. We apply the right treatment before testing, and counsel confirms it where the result is close.
Benefits Next to the Trust’s
Non-union employees compare their plan with the trust’s. We benchmark the two, because a promotion that comes with worse coverage is a hard one to accept.
One Place for Questions
Employees who have been in both plans need one place to ask about either. Their questions come to our team, so HR is not left interpreting a trust plan it does not control.
What employers with union and non-union staff ask.
Can non-union employees join the trust plan?
Some trusts allow it through a participation agreement and some do not. The trust documents decide, and we compare that option with your own plan before you ask.
Who covers an employee who moves mid-month?
Both sides may have obligations for that month. We set a written rule for transfer dates, so the trust remittance and your plan’s eligibility agree.
Does the trust’s plan year have to match ours?
No, and it rarely will. What has to match is how you handle the move between them, which is why we write it into your plan documents.
Also in Compliance & Oversight
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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