The U.S. Department of Labor has issued an advisory opinion finding that a group health plan proposed by the Idaho Farm Bureau Federation for its members’ employees would be considered an employee welfare benefit plan under federal law.
The department’s Employee Benefits Security Administration determined in the advisory opinion that, if established, the IFBF’s proposed plan for employees of its 10,770 members would be an employee welfare benefit plan under the Employee Retirement Income Security Act. The IFBF may now rely on this guidance to establish the plan.
This advisory opinion advances President Donald Trump’s mission of providing better healthcare at lower costs to small businesses.
“This guidance will expand access to quality, affordable health coverage to farmers, ranchers, and agricultural tenants and landowners, across Idaho and may be used by other groups across America,” said Assistant Secretary for Employee Benefits Security Daniel Aronowitz. “This is an innovative model that expands access to employer sponsored coverage, especially for small businesses, by reducing regulatory complexity and the cost of health coverage.”
Eligibility for participation in the plan will be limited to IFBF members who are actively engaged in agricultural production in Idaho, employ at least two full-time employees, and sign a participation agreement.
By signing this agreement, each participating employer will also become a member of the consortium overseeing the plan. The consortium will serve as the plan sponsor and delegate fiduciary and administrative roles to the consortium’s benefits committee.
EBSA’s Office of Regulations and Interpretations answers inquiries from individuals and organizations in the form of advisory opinions, which apply the law to a specific set of facts, or information letters, which merely call attention to well established principles or interpretations.
Read Advisory Opinion 2026-01A.