As we look ahead to 2015, the employer shared responsibility rules under the Affordable Care Act will have a greater impact on large employers. In regards to the requirement faced by employers to offer affordable, minimum value health coverage to full-time employees and dependents, the IRS has provided multiple safe harbor methods that can be used to determine full-time employee status.
Under Notice 2014-49, the IRS issued proposed approaches for applying the look-back measurement method if the measurement period for a particular employee changes.
When an Employee Changes Positions
One of the key items addressed in this notice is in regards to what needs to be done if an employee changes to a job position that uses a different measurement period.
Here is an overview of what the notice says about these situations:
- For an employee who is in a stability period (or administrative period) at the time of transfer, the employee retains his or her status through the end of that stability period
- For an employee who is not in a stability period (or administrative period) at the time of transfer, the employee’s status is determined using the measurement period applicable to the second position, but including hours of service in the first position
- If a new variable hour, part-time or seasonal employee transfers during the initial measurement period to a second position in which he or she is reasonably expected to be full-time, the general look-back measurement method rules apply
Additional Information
I hope that you find this brief summary helpful. Please note that the IRS notice also provides insight on employers that want to change the measurement period for a category of employees.
To access our full Compliance Bulletin on this topic, please visit the CBGconnect portal, or contact our team.