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Shared Services Multi-Employer plan

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I am a benefit consultant who has been approached by two colleges who are currently participating in a self insured captive with other colleges for Health & Welfare benefits.  They would like to leave the health insurance captive, continuing to operate independently, but wish to create a new organization for shared services (finance, HR, IT, etc) that would service both colleges as well as potentially be a product they could offer (sell) to other colleges.  This new, shared services organization will have less than 100 employees (100 FTEs required in NYS for stop loss).  Does anyone have any ideas for the best path that would enable these two colleges to continue to operate independently, but for their to be common control (i.e. a parent organization) that is set up over both colleges and the new shared services organization so that from an employee count perspective, all 3 groups could be considered as one and the new shared services organization also be permitted to be self insured with stop loss?  

Are there any other paths that reach this same end that don't involve common control?

Thanks in advance for any help you can provide!

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I moved this to the healthcare board.  It might be better responses on that board.  Not really a "multiemployer" question, which are a specific type of pension plan for collectively bargained groups.

The material provided and the opinions expressed in this post are for general informational purposes only and should not be used or relied upon as the basis for any action or inaction. You should obtain appropriate tax, legal, or other professional advice.

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