Setting the Scene

A production company, a crew of hundreds, and a compliance clock ticking

Picture a mid-size entertainment employer — a signatory production company managing multiple overlapping projects. At any given time, dozens of crew members are cycling on and off productions. Some work 60-hour weeks for three months straight. Others are called in for a few days here, a week there. Some hold simultaneous engagements across two or three productions under the same employer umbrella.

This is the everyday reality for EIEA member companies. And woven through all of it — invisibly, critically — is a compliance obligation that hinges entirely on one thing: knowing exactly how many hours each of those workers has logged.

That’s where payroll tracking becomes not just an operational function, but the foundation of healthcare coverage compliance.

Why payroll data drives coverage

Hours aren’t just a paycheck calculation — they’re an eligibility trigger

Under the Affordable Care Act, applicable large employers (ALEs) — those with 101 or more full-time employees and full-time equivalents — must offer minimum essential coverage to employees averaging 30 or more hours per week. Miss that threshold determination, and the consequences range from a coverage gap for the employee to a significant penalty assessment for the employer under IRC Section 4980H.

The only way to make that determination accurately is through disciplined, continuous payroll tracking. Every hour recorded, every pay period closed, every payroll register filed — these are not just accounting entries. They are the raw data from which ACA eligibility is built.

In the entertainment industry, hours can be irregular, production-specific, and spread across multiple payroll companies or signatories. EIEA’s tracking infrastructure is designed precisely to aggregate that fragmented data into a single, defensible compliance picture.

How the Process Works

From timecard to coverage determination: the compliance chain

• Hours are recorded at the production level
  Every hour worked — whether on a feature film, a commercial shoot, or a streaming series — is captured through the production’s payroll system.
• Payroll data is transmitted to EIEA
  Member companies transmit payroll registers to EIEA on a recurring basis. This includes each worker’s hours, earnings, job classification, hire date, and termination date.
• Hours are aggregated and measured
  EIEA consolidates hours across all productions for each individual worker. Using the look-back measurement method, total hours are evaluated over the defined measurement period to determine whether the employee meets the full-time threshold.
• Eligibility is determined and coverage is offered
  Workers who average 30 or more hours per week during the measurement period are flagged as ACA-eligible an the EIEA automatically offers coverage.
• Data flows into annual ACA reporting
  The same payroll data that drove eligibility determinations feeds directly into Forms 1094-C and 1095-C — the annual IRS filings that document every offer of coverage made to every full-time employee throughout the year.

The EIEA’s Role

Infrastructure that individual employers can’t build alone

No single production company has the infrastructure to track every hour, across every show, for every worker — and then connect it all to a benefits offering and a federal filing. That’s exactly what EIEA was built to do.

For entertainment industry employers, payroll tracking is not a back-office problem — it’s a front-line compliance function. The hours recorded today determine the coverage offers due in the next stability period. The payroll data submitted this quarter determines the accuracy of the 1095-C filed next January.

EIEA’s model brings together signatory employers under a shared compliance infrastructure: standardized data collection, centralized hour aggregation, measurement period management, and fully coordinated ACA reporting. Members don’t have to build that capability themselves — they access it through EIEA’s platform and expertise.

The result is a system where payroll tracking is no longer just about cutting checks. It’s about protecting employees’ access to coverage, protecting employers from penalty exposure, and building the kind of documented compliance record that holds up under scrutiny.

For EIEA members, every payroll register submitted is a compliance action. It’s how hours become eligibility, and eligibility becomes coverage — and coverage becomes the documented, reportable proof of an employer meeting its ACA obligations.

Entertainment Industry Employers Association (EIEA) — serving large group employers with 101+ full-time employees and full-time equivalents across the entertainment industry.

The Basics of Large Group and Small Group

Not all group health plans are created equal

When it comes to employer-sponsored health insurance, the size of your workforce determines far more than just your premium — it shapes which rules apply to your plan, what protections your employees receive, and what obligations fall on you as an employer. The distinction between large group and small group coverage is one of the most important — and most misunderstood — lines in healthcare law.

Understanding where your organization falls isn’t just an administrative detail. It’s the foundation of your entire benefits strategy.

Defining the Groups

Where does your organization fall?

Under the Affordable Care Act, group size thresholds vary by state, but the federal framework draws a clear line. Small group plans generally cover employers with 1–100 full-time employees and full-time equivalents (FTEs). Large group plans cover employers above that threshold. In California and several other states, the large group market begins at 101 or more full-time employees and FTEs.

Key Differences

How the rules diverge

Small group plans are subject to strict ACA market reforms. Insurers must cover the ten essential health benefits, cannot vary premiums based on health status or claims history, and must apply modified community rating — meaning rates are based primarily on age and geography, not on the risk profile of the group. This creates a degree of predictability for small employers, but also less ability to customize.

Large group plans operate under a different set of rules. Insurers can experience-rate large group plans, meaning your actual claims history directly influences your premiums. This creates greater variability — but also greater opportunity. Employers with healthy, well-managed workforces can see that reflected in their costs. Plans can be more flexibly designed, and coverage features can be tailored to the specific workforce.

Large group employers also carry the employer mandate under the ACA. As applicable large employers (ALEs), they must offer minimum essential coverage meeting minimum value standards to full-time employees — or face potential penalties under IRC Section 4980H.

The Entertainment Industry Context

Why this distinction matters for EIEA members

The entertainment industry presents a uniquely complex benefits landscape. Productions spin up and wind down. Workers hold multiple engagements across multiple employers in a single year. Tracking who qualifies as full-time — and ensuring coverage is offered at the right time — requires infrastructure that most individual production companies cannot maintain alone.

EIEA exclusively serves large group employers: those with 101 or more full-time employees and full-time equivalents. Our members operate in the large group market, which means they benefit from experience-rated plans, greater plan design flexibility, and the ability to leverage pooled workforce data to manage costs strategically. It also means they carry the compliance obligations that come with ALE status — from ACA tracking and reporting to 1094-C and 1095-C filings.

EIEA’s role is to make large group compliance manageable — providing the tracking infrastructure, employer coalition, and benefits expertise that allows entertainment industry employers to meet their obligations without building that capability from scratch.

Bottom Line

Know your market, know your obligations

Whether an employer falls into the small group or large group market is not just a matter of headcount — it determines the regulatory framework, the structure of available plans, and the compliance requirements that govern every benefits decision. For employers in the entertainment industry operating at the large group level, having the right partner to navigate that landscape makes all the difference.

Entertainment Industry Employers Association (EIEA) — serving large group employers with 101+ full-time employees and full-time equivalents.

DEFINING ELIGIBILITY

Who Qualifies Under the ACA?

Under the Affordable Care Act, applicable large employers (ALEs) — those with 50 or more full-time equivalent employees — are required to offer minimum essential coverage to full-time employees or risk penalties. A full-time employee is defined as someone who works an average of 30 or more hours per week, or 130 hours per month. In the entertainment industry, where workers frequently move between productions, projects, and short-term engagements, determining who meets that threshold is rarely straightforward. That’s why systematic tracking is not just best practice — it’s essential.

MEASUREMENT PERIODS

Counting Hours the Right Way

The IRS provides two methods for tracking employee hours to determine ACA eligibility: the monthly measurement method and the look-back measurement method. The look-back method is particularly useful for variable-hour and seasonal workers — a common reality in entertainment. It allows employers to observe an employee’s hours over a defined measurement period (typically 3–12 months) before determining their status for a subsequent coverage period. This gives employers a structured, defensible approach to eligibility determinations when work schedules are unpredictable.

STABILITY PERIOD

Locking in Coverage Status

Once an employee is determined to be full-time during the measurement period, they must be offered coverage for the entirety of the subsequent stability period — regardless of how many hours they actually work during that window. The stability period must be at least six months and no shorter than the measurement period itself. This protects employees from losing coverage mid-year due to fluctuating schedules, and it protects employers who follow the process correctly from inadvertent ACA penalties.

DATA COLLECTION

The Foundation of Compliance

Accurate, consistent data collection is the backbone of ACA compliance. Employers must track hours of service for every employee — including hourly, salaried, and variable-hour workers — and maintain those records with precision. For EIEA members, this means aggregating data across productions, payroll companies, and signatories. Tracking systems must capture hire dates, termination dates, hours worked, and any applicable waiting periods. Without reliable data, measurement periods and eligibility determinations are impossible to defend in an audit.

REPORTING

Forms 1094-C and 1095-C

All of this tracking culminates in annual ACA reporting obligations. Applicable large employers must file two key forms with the IRS each year:

• Form 1094-C
  Transmittal Form
  Filed with the IRS as a cover sheet summarizing the employer’s offer of coverage and aggregated employee data across the reporting year.
• Form 1095-C
  Employee Statement
  Issued to each full-time employee, detailing the coverage offered, employee cost, and months of coverage — used when filing personal tax returns.

Deadlines, accuracy, and completeness all matter. Errors or late filings can trigger IRS penalties under Sections 6721 and 6722. For EIEA members, coordinating this reporting across a fragmented workforce makes early data collection and strong administrative infrastructure a year-round priority — not just a January scramble.

ACA compliance in entertainment isn’t a once-a-year task. It’s a continuous process of tracking, measuring, and reporting — and EIEA is here to support members every step of the way.

Entertainment Industry Employers Association (EIEA)  |  ACA Compliance Resources

COBRA – the Consolidated Omnibus Budget Reconciliation Act – requires group health plans to offer continuation coverage to covered employees, former employees, spouses, former spouses, and dependent children when group health coverage would otherwise be lost due to certain events. Those events include:

• A covered employee’s death,
• A covered employee’s job loss or reduction in hours for reasons other than gross misconduct,
• A covered employee’s becoming entitled to Medicare,
• A covered employee’s divorce or legal separation, and
• A child’s loss of dependent status (and therefore coverage) under the plan.

COBRA sets rules for how and when plan sponsors must offer and provide continuation coverage, how employees and their families may elect continuation coverage, and what circumstances justify terminating continuation coverage.

Employers may require individuals to pay for COBRA continuation coverage. Premiums cannot exceed the full cost of the coverage, plus a 2 percent administration charge.

Group Health Plans Subject to COBRA

COBRA generally applies to all private sector group health plans maintained by employers that had at least 20 employees on more than 50 percent of its typical business days in the previous calendar year. Both full- and part-time employees are counted to determine whether a plan is subject to COBRA. Each part-time employee counts as a fraction of a full-time employee, with the fraction equal to the number of hours worked divided by the hours an employee must work to be considered full time. For example, if full-time employees at Company A work 40 hours per week, a part-time employee who works 20 hours per week counts as half of a full-time employee, and a part-time worker who works 16 hours per week counts as four-tenths of a full-time employee.

COBRA also applies to plans sponsored by state and local governments.⁽¹⁾ The law does not apply, however, to plans sponsored by the federal government or by churches and certain church-related organizations.

What is a group health plan? It is any arrangement that an employer establishes or maintains to provide employees or their families with medical care, whether it is provided through insurance, by a health maintenance organization, out of the employer’s assets, or through any other means. “Medical care” includes for this purpose:

• Inpatient and outpatient hospital care,
• Physician care,
• Surgery and other major medical benefits,
• Prescription drugs, and
• Dental and vision care.

Life insurance and disability benefits are not considered “medical care.” COBRA does not cover plans that provide only life insurance or disability benefits.

COBRA-covered group health plans that are sponsored by private-sector employers are generally considered welfare plans under ERISA and therefore subject to ERISA’s other requirements. Under ERISA, group health plans must be administered by a plan administrator, who is usually named in the plan documents. Many group health plans are administered by the employer that sponsors the plan, but group health plans are also frequently administered, in whole or in part, by a separate individual or organization, such as a professional benefits administration firm. Carrying out the requirements of COBRA is the direct responsibility of the plan administrator.

Source –
An Employer’s Guide to Group Health Continuation Coverage Under COBRA

If you’ve ever been told that a medication, test or procedure needs “prior authorization,” you’re not alone. It’s a common part of using health insurance, but it can still be inconvenient to many people. In fact, a 2026 KFF poll found that 1 in 3 insured adults say prior authorizations are a “major burden” for getting health care. An additional 4 in 10 adults say that prior authorization is a “minor burden,” meaning about 7 in 10 adults find the process taxing.  

While prior authorization can feel like an extra hurdle, understanding how it works can help you avoid surprises and get the care you need with less stress. This article explains prior authorization, including why and when the process is needed.

What Is Prior Authorization?

Prior authorization may also be referred to as preauthorization, precertification or prior approval. Prior authorization is a process where your doctor must get approval from your health insurance before your plan will cover certain medications, treatments or services. It acts as a green light confirming that the care you’re about to receive is something your insurance plan considers appropriate and eligible for coverage.

“Step therapy” is another term you may hear when seeking health care. Step therapy is a type of prior authorization in which an insurance company has you try less expensive prescription options before “stepping up” to costlier drugs. Basically, the health plan won’t cover the more expensive drug until the lower-cost medication has failed to treat the condition.  

Here’s a simple breakdown of what usually happens during the prior authorization process:  

• Your doctor recommends care that may need approval.
• Your doctor’s office submits paperwork to your insurance plan.
• The insurer reviews the request, checking it against their clinical guidelines.

You and your doctor receive a decision that’s an approval, a denial or a request for more information.   The process may involve different steps, depending on whether the doctor, the lab or a third-party service handles the request. Regardless, the goal is the same: confirming that the plan will cover the care. If the care you need is urgent, most states’ laws require the insurance company to respond within 1 to 3 days; however, if the care isn’t urgent, the company may take up to a few weeks.  

While the prior authorization process helps control costs and reduce unnecessary care, it can also delay care if information is missing or the insurance company needs more details.  

When Is Prior Authorization Needed?

• Prescription drugs, especially newer, higher-risk or more expensive medications
• Imaging tests like MRI or CT scans
• Planned surgeries or hospital stays
• Specialty treatments or durable medical equipment  

Who Handles the Prior Authorization Process?

What if a Prior Authorization Is Denied?  

• Submit more information if something was missing.
• Appeal the decision and explain why the treatment is necessary.
• Explore alternatives that are covered by the plan, such as meeting step therapy requirements.

Why Is Prior Authorization Required?  

Conclusion  

This Compliance Overview is not intended to be exhaustive nor should any discussion or opinions be construed as legal advice. Readers should contact legal counsel for legal advice.

©2025 Zywave, Inc. All rights reserved.

Open Health Provides Coverage for Non-Union Employees; Simplifies Sign-Up, Budgeting and Ongoing Administrative Burden for Employers

BURBANK, Calif., November, 4, 2014 – Cast & Crew Entertainment Services, the premier provider of payroll and production accounting services to the entertainment industry, today announced the launch of Cast & Crew Open Health (the “Plan”) (www.cc-openhealth.com), a unique Affordable Care Act-compliant health care insurance offering. The Plan brings to the industry several solutions – simplified sign-up, budgeting and administrative responsibility – not available from any other plan.

The Plan, which is eligible for most state tax-incentive programs, provides coverage for all non-union employees working in the entertainment industry. It is portable for the employer irrespective of payroll-service provider. It also is portable for employees who become covered under the Plan.

Under the employer responsibility requirements of the ACA, large employers must provide health insurance for their employees, or pay a penalty. The penalties are scheduled to go into effect on January 1, 2015.

“The ACA presents very specific challenges to our industry, given its transient workforce,” said Eric Belcher, President and Chief Executive Officer. “To ensure we clearly understood employer concerns and objectives before rushing to market with a quick-fix product or one that doesn’t work, we talked with numerous studios and production companies over the past several months so we could develop a comprehensive solution.

“Employers told us they want a simple solution that eliminates the administrative burden, so they can focus on their productions – not the ACA. Cast & Crew Open Health does that. They also told us they want it to address the very specific employee challenges we have as an industry. I am pleased to say Cast & Crew Open Health addresses their objectives: We’ve simplified the process. It’s an industry solution. And employers can ensure they are compliant with the ACA.”

To bring this type of coverage to the industry, Cast & Crew established the Plan as a multiple-employer health plan. The Plan is designed to provide medical coverage that satisfies ACA requirements to all non-union employees who are required to be offered coverage under the ACA. Accordingly, employers can ensure ACA compliance by participating in the Plan. This is the only plan of its kind offering the non-unionproduction employees a guild-like program.

This structure, developed with leading insurance brokers, attorneys and other insurance and entertainment human resources experts, enables Cast & Crew Open Health to provide employers with large-group pricing and benefits that are superior to market-based coverage that can be obtained elsewhere. The Plan’s fee structure is based on a percentage of gross wages, a structure familiar to the industry.

“Cast & Crew Open Health simplifies budgeting and significantly lessens employers’ administrative burdens,” added Shardell Cavaliere, Senior Vice President, Client Relations at Cast & Crew Entertainment Services and a member of the Board of

Trustees of the Plan. “It removes the need to track employee hiring status and terminations, and because it is billed as a fringe there is no need to allocate premiums down to productions. Cast & Crew Open Health provides the entertainment industry with a one-of-a-kind solution not available elsewhere.”

The Plan complies with ERISA, the ACA and other applicable law and is funded through a trust established for the exclusive benefit of the participants. The trust will hold all the insurance contracts and be a conduit for payment of premiums.

Coverage is provided through Anthem Blue Cross and includes HMO/PPO options as well as optional dental, vision and life. Enrolled individuals will have access to the largest national network in the country, with more than 900,000 providers. Anthem members, moreover, have access to more than 90 percent of hospitals and 90 percent of physicians nationwide – more than any other insurer. Cast & Crew Open Health and Anthem Blue Cross provide employer and employee support through various communication methods, including email, a 24×7 phone center and online assistance.

The Plan is part of the company’s Cast & Crew Complete benefits-management suite. Another component is Cast & Crew ACA SureTrack, which is a comprehensive online ACA management system.

The Plan was developed with The Henehan Company and The Miles Organization, which evaluate, design, implement and administer employee benefit plans.

About Cast & Crew

Cast & Crew Entertainment Services, LLC (www.castandcrew.com) is the premier provider of payroll and related services to the entertainment industry. It is owned by an investor group led by ZM Capital, ZelnickMedia’s private equity fund. Cast & Crew is the leading provider of technology-enabled payroll and related business services to film and TV productions. Cast & Crew’s services include payroll processing, residuals, workers’ compensation, labor relations, production incentives, as well as financing production tax credits. Cast & Crew’s PSL production accounting software is the industry-leading accounting application to serve the needs of the film, television and digital media industries. The company, which was founded in 1976, owns and operates each of its offices – eight in the U.S., two in Canada and one in the U.K. Cast & Crew’s corporate headquarters are in Burbank, California.