By Scott Sweeney, VP, Senior Sales Executive at Marshall+Sterling
Estimated reading time: 5 minutes
Summer is weeks away. Pre-season checklists are getting done, waterfront is ready, the vans are inspected, the dining hall is set. But there’s a different category of risk that’s getting less attention at most camps this season: the workforce itself.
Several overlapping pressures including disruptions to international staffing programs, documentation compliance requirements, and employment practices exposure are converging in 2026 in a way that most camp risk programs haven’t specifically planned for. None of them are catastrophic on their own. Together, they create a risk picture that’s worth a conversation before your first staff member arrives.
Here’s what to put on your radar.
J-1 Visa Disruptions and the Downstream Risk They Create
Many Northeast residential camps rely on J-1 cultural exchange participants for a meaningful portion of their counselor and program staff. In 2026, J-1 processing disruptions and program uncertainty have created last-minute staffing gaps at camps that planned their season around international staff ratios that didn’t fully materialize.
The immediate operational problem is obvious: you’re short counselors. The less-obvious problem is what that shortage does to your risk profile.
When staffing gaps get filled quickly, with less-screened domestic hires, with counselors moved out of their trained positions, or with supervision ratios that are technically met but operationally thin, the risk profile of your camp changes. Compressed onboarding shortens training time. Moved staff take on waterfront or activity roles they haven’t been vetted for. Ratios that look fine on paper translate into real supervision gaps in the field.
From a coverage standpoint: if your staffing composition has changed materially since you completed your application with your carrier, that’s a conversation worth having with your broker before season opens, not at renewal. Your policy reflects the operation you described when you applied. Material changes to your staffing model are worth flagging.
Before opening day: Confirm your counselor-to-camper ratios are achievable with your confirmed staffing, not your planned staffing. Identify gaps now, while there’s still time to address them.
I-9 Compliance: The Documentation Task Most Camps Defer
Every employee at your camp — regardless of nationality or visa status — requires a properly completed Form I-9. It’s a federal requirement, not an optional administrative task, and the penalties for non-compliance are real: civil fines per violation, and criminal liability for pattern violations.
Camp-specific I-9 gaps tend to cluster in predictable places:
- Returning staff whose work authorization documents expired between seasons, re-hired without re-verification.
- Forms completed late: I-9s must be completed by the employee’s first day of work (Section 1) and by the third business day of employment (Section 2).
- Improper document acceptance: accepting documents that don’t appear on the acceptable documents list, or accepting documents that have clearly expired.
- J-1 and other visa holders whose work authorization expires mid-season and whose re-verification gets missed during the operational chaos of a running camp.
In the current federal enforcement environment, I-9 documentation is a stronger operational priority than it has been in prior seasons. Enforcement activity is elevated, and camps (as employers of large seasonal workforces, often with significant international staffing) are the kind of work environments that can draw attention.
Before opening day: Run an I-9 audit across all staff — new hires and returning staff alike. Assign a designated staff member to manage I-9 compliance throughout the season. If you have questions about your specific compliance posture or any enforcement-related procedures, consult employment counsel.
EPLI: The Coverage Most Camps Either Don’t Have or Don’t Understand
Employment Practices Liability Insurance responds to claims brought by employees for wrongful termination, discrimination, harassment, retaliation, and related employment matters. In a normal camp season, EPLI sits quietly in the policy stack. In 2026, several factors are elevating EPLI exposure specifically at camps.
Why EPLI risk is elevated this season:
- Rapid, compressed hiring creates a higher likelihood of inconsistent onboarding, unclear job expectations, and poorly documented performance standards, all of which create wrongful-termination exposure when a staff member is let go mid-season.
- Staffing restructures (when camps lose J-1 workers and reorganize) can look like discriminatory treatment if not documented carefully.
- A workforce that’s operating under strain (overloaded supervisors, undertrained staff, long season hours) is a workforce where harassment and hostile-workplace complaints are statistically more likely.
- Heightened staff sensitivity around workplace conditions and rights is not limited to the corporate world; it’s showing up in camp staff populations too.
What to check on your EPLI policy:
- Do you have it? EPLI is often absent from smaller camp programs, or written at limits that don’t reflect the size of the operation.
- What does it cover? Confirm it includes wrongful termination, discrimination, and harassment, and ask specifically whether it covers third-party claims (a camper family claiming harassment by a staff member, for example).
- Does it include wage and hour? Wage and hour claims such as unpaid overtime and break violations are a growing source of EPLI exposure for seasonal employers. Not all policies include this coverage.
- Does it include an HR advisory hotline? Some EPLI policies include access to an employment counsel hotline you can call before making a difficult personnel decision. This is one of the most practical risk-management tools in the policy
If you’re uncertain whether your EPLI coverage is structured correctly for a camp operation, pre-season is the right time to ask. Not July.
We’re Here If You Have Questions
Workforce risk isn’t where most camp insurance conversations start. But it’s where some of the most consequential claims originate, and it’s an area where a quick pre-season review with your broker can surface problems that are far cheaper to fix now than in August.
If any of this raises questions about your current program, our camps practice would welcome the conversation. We work with camp owners and directors year-round, not just at renewal.
This article is for informational purposes only and is not intended as legal, tax, or insurance advice. I-9 compliance requirements, EPLI coverage terms, and the implications of any enforcement activity are subject to federal law and vary by circumstance. Consult qualified employment counsel and your Marshall+Sterling advisor before making compliance or coverage decisions.
