Holland & Hart represented the Idaho Farm Bureau Federation (IFBF) in obtaining an advisory opinion from the U.S. Department of Labor's Employee Benefits Security Administration, clearing the way for IFBF to establish an association health plan for its nearly 11,000 member businesses across Idaho. This opinion is the first of its kind to be issued to any of the 50 state Farm Bureau Federations.
The EBSA advisory opinion, issued May 1, 2026, confirmed that IFBF's proposed plan qualifies as an employee welfare benefit plan and a multiple employer welfare arrangement under the Employee Retirement Income Security Act (ERISA). According to the advisory opinion, the proposed plan will provide fully insured group health coverage through Blue Cross of Idaho Health Service, Inc. to employees of participating employer members, including farmers, ranchers, and agricultural landowners across Idaho.
The stringent requirements of ERISA presented significant legal obstacles to establishing the plan. In a creative solution, Holland & Hart structured an entirely new employer sub-association, the IFBF Employer Consortium, within the broader federation—demonstrating to the DOL that the sub-group satisfied ERISA's "bona fide" association standards by virtue of the federation's 80-year history of collaboration among Idaho's agricultural community.
The DOL noted the opinion "may be used by other groups across America," and Assistant Secretary for Employee Benefits Security Daniel Aronowitz called it "an innovative model that expands access to employer-sponsored coverage, especially for small businesses, by reducing regulatory complexity and the cost of health coverage."
The Holland & Hart team was led by partner Gabriel Hamilton.
Holland & Hart's Employee Benefits attorneys advise a broad range of clients—including private and publicly traded employers, government entities, small businesses, and tax-exempt organizations—on the creation and administration of customized retirement plans, multiemployer plans, medical benefit plans, and other employee benefit plans. When problems arise, the team defends clients before the Internal Revenue Service, the Employee Benefits Security Administration, and the Pension Benefit Guaranty Corporation.