I think I know the answer, I just need some reassurance and some guidance to citations, if possible.

There are a group of attorneys who have support staff. The company wants to offer and pay for health insurance for the support staff only and not pay for health insurance for the attorneys.

From what I can tell, there would be no discrimination testing b/c the insurance would be provided 100% through health insurance. Also, I'm assuming that attorneys vs. support staff would be an acceptable classification.

Any thoughts?

Just make sure that you don't have a HIPAA discrimination problem in drawing that distinction. That will depend perhaps on the health status of the excluded attorneys as compared to the included staff.

From a tax perspective, no problem.

I would suggest checking with your carrier participation rules. Depending on the carrier, and the size of your group, you may not meet the requirements.