Governmental plans are not ERISA plans, and half the checklist does not apply.
Municipalities, townships, authorities, districts and public agencies. The compliance obligations you actually carry are a different set from the one a private employer carries, and advice written for private employers routinely gets this wrong in both directions.
Fewer rules than you are being sold. Not none.
What Is Actually True for a Governmental Plan
- Governmental plans are exempt from ERISA, so the plan document, summary plan description and Form 5500 machinery that drives private-sector compliance calendars does not apply in the same way.
- The obligations that do apply still bite: the employer mandate and 1095-C reporting, COBRA, Medicare secondary payer rules and the Part D creditable coverage disclosure.
- Plan changes are frequently a bargaining matter and a public one, with a meeting schedule and a record the renewal has to fit.
- Workforces are long-tenured, so the age curve, retiree coverage and the Medicare interaction are central rather than peripheral.
What CFH Does About It
- Applies the governmental-plan exemption correctly instead of running a private-sector checklist at you.
- Keeps the obligations that do apply on their own calendar, sourced to the agency that owns each one.
- Works the renewal to the meeting and bargaining calendar so a decision can actually be taken.
- Models the retiree and Medicare position alongside the active plan.
See how we work a whole benefits program →
Retiree medical, GASB 75 and what moves the OPEB number →
What the Public Act 152 cap actually limits →
Six Industries We Serve in Public Administration.
Each industry below has its own guide to eligibility, funding, compliance and retention for employers like yours.
City Village and Township
Benefits planning, eligibility rules and cost control for city village and township employers.
County Government
Benefits planning, eligibility rules and cost control for county government employers.
Police and Fire Employee Benefits Collective Bargaining
Benefits planning, eligibility rules and cost control for police and fire employee benefits collective bargaining employers.
Public Authority and Special District
Benefits planning, eligibility rules and cost control for public authority and special district employers.
School District
Benefits planning, eligibility rules and cost control for school district employers.
Road Commission and Public Works
Benefits planning, eligibility rules and cost control for road commission and public works employers.
Four sizes, four different problems.
Find your headcount. What changes at that size in this industry, and what we do about it.
A small township or authority is community-rated, and an older workforce sits at the wrong end of the age band.
What we do about it: Prices the market annually and gets the Part D disclosure onto its own calendar.
The employer mandate and 1095-C reporting apply here the same as anywhere, even though ERISA does not.
What we do about it: Runs the obligations that apply and stops you paying for the ones that do not.
Self-funding becomes realistic, and a stable public workforce’s experience is an advantage in that analysis.
What we do about it: Models funding on your own claims and brings the decision in a form the board can adopt in public.
Several departments, bargained and non-bargained groups, and a retiree population alongside the active one.
What we do about it: Runs them as one program with one documented process and one calendar.
Public employers we serve, one page each.
Housing Commission and Public Housing Authority
Employee benefits for Michigan housing commissions and public housing authorities: contribution rules, board approval, retiree promises and plan options.
Water and Wastewater Treatment Operator
Group health benefits for Michigan water and wastewater treatment operators: licensed staff, shift coverage, and public sector rules.
Tribal Government and Casino Employer
Group health insurance and benefits for Michigan tribal governments, tribal enterprises and casino employers: plan status, large hourly workforces and funding options.
Commuter and transit benefits: what employers can offer and how it works
What commuter and transit benefits employers can offer, how pre-tax commuting accounts work and what to ask your tax advisor.
Public and Affordable Housing
Employee benefits for Michigan housing commissions, nonprofit owners, management companies and supportive housing teams: plan design, funding and compliance.
The three things employers in this sector ask us first.
Which federal requirements actually apply to a governmental plan?
The employer mandate and 1095-C reporting, COBRA, Medicare secondary payer rules and the Part D disclosure. ERISA’s plan document, summary plan description and Form 5500 requirements generally do not. State law can add its own layer: in Michigan, the Public Act 152 cap limits what a public employer can pay toward medical coverage, unless a city, village, township or county votes each year to exempt itself. We keep those rules on the same calendar as the federal list.
How do we handle retirees and Medicare-eligible employees who are still working?
With the Part D notice on its own calendar and the retiree position modeled alongside the active plan rather than separately. For employees still working after they become Medicare-eligible, the active plan generally pays first at an employer large enough to fall under the Medicare secondary payer rules, so their enrollment choices need explaining before they sign up for Medicare. Retiree coverage also feeds the OPEB figures, so plan changes are modeled for both.
Can a renewal be worked to fit our meeting and bargaining schedule?
Yes, and it has to be. We start early enough that a decision can be taken in public, on the record, at a scheduled meeting. We work back from the meeting date: carrier quotes, the recommendation and a board-ready summary are timed to the agenda deadline, and any bargaining notice periods are built into the plan.
Where the Rules Come From.
The laws and rules named on this page link to the statute or regulation they come from. This is general information, not legal or tax advice, and rules change, so check the current text.
ERISA (29 U.S.C. Chapter 18)
The federal law that sets reporting, disclosure and fiduciary rules for employer-sponsored benefit plans.
COBRA Continuation Coverage (29 U.S.C. 1161)
Requires many group health plans to offer temporary continuation coverage after a qualifying event.
ACA Reporting (26 U.S.C. 6056)
The statute behind employer reporting of offers of coverage on Forms 1094-C and 1095-C.
Plan Reporting (29 CFR Part 2520)
The Department of Labor rules for annual plan reports, including Form 5500.
Creditable Prescription Coverage (42 CFR 423.56)
Defines creditable coverage for Medicare Part D disclosure and notice rules.
Publicly Funded Health Insurance Contribution Act (MCL 15.561)
Michigan’s public-employer cap on health plan costs, known as Public Act 152 of 2011.
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. →