Large employers do not have to treat all employees the same.
They can offer different benefits to different classes of employees.
They can offer management carve-outs, where managers are offered benefits and non-management employees are not.
Note: failure to offer coverage to at least 95% of full-time employees can result in an across-the-board penalty under IRC 4980H(a) – the employer mandate’s sledgehammer penalty.
Large employers with a management carve-out should not have a 125 plan in place as it would fail discrimination testing.