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What DOL rules are you concerned about violating...in paragraph one?
Discrimination in providing benefits equally? Each of these owners has said they want to pay for benefits for half of their employees at the most. Each has all employees working over 30 hours a week.
I recall a seminar at NAHU conference talking about rules that don't allow manipulating hours to look like some are full and some are part time when it doesn't match reality. So the only way would be to make some salary, then exclude hourly employees, but the owners don't want to do that. In off season, they want to pay everyone just when they work.
Do you have a suggestion for rewarding the ones they want to be sure to keep on board, and still being compliant? As it stands now, one of the contractors has agreed to look at plans where the employer share would be 50% of EE premium. the owner and top manager are each paying about $300/month now on individual POS plans I wrote for them, no tax credits, both make good salaries, owner is on payroll, too.