Aftermarket Insider Issue 83 - (Page 3)
insurance understanding
indUSTRy nEwS
Affordable Care Act:
Determination of Full-Time Employees
B Y A n I TA B Ak E R , C PA , C lI FTo n lA R So nAll E n llP
period from three to 12 months.
The Patient Protection and
If an employee is full-time during
Affordable Care Act (ACA) contains
the measurement period, then the
a number of provisions that are
employer must offer health coverage
dependent on the number of full-time
during the subsequent stability period,
employees at a company. The number
which is the greater of six months or
of full-time employees and full-time
the measurement period, to all fullequivalents (FTEs) determines whether
time employees to avoid penalties.
or not the employer is a “large”
employer (50 or more FTEs) and
• New Full-Time Employees (excluding
subject to the shared responsibility
seasonal workers): If it is reasonably
provisions. Large employers must offer
expected that an employee will
insurance to full-time employees or they
average at least 30 hours per week,
could be subject to a penalty beginning
then an employer would need to offer
in 2015. The employer mandate and
health coverage within the 90-day
penalties were originally effective Jan.
waiting period to avoid penalties.
1, 2014; however, the Internal Revenue
• New Variable-Hour and Seasonal
Service (IRS) announced on July 2,
Employees: If an employer cannot
2013, that these rules would be delayed
make a reasonable determination at
for one year. However, it is still critical
the start date of whether an employee
to understand how full-time employees
will average at least 30 hours per
are determined under ACA.
week, then the employee falls into
this category. Similar to ongoing
A full-time employee is an individual
employees, the employer will set an
averaging at least 30 hours of service
initial measurement period that
per week or 130 hours of service per
would determine full-time
month. For many employees, this can
status for the subsequent
be a simple determination. However,
stability period.
for employees who fluctuate in hours
or are only employed seasonally, the
determination is more involved.
To handle these types of situations,
current IRS guidance provides
a safe harbor look-back method
that an employer can use since the
determination of full-time employees
on a month-to-month basis would be
difficult. The following categories of
employees and methods may be used to
determine who is a full-time employee:
With questions, please contact Anita
Baker, CliftonLarsonAllen, at anita.
baker@CLAconnect.com, or call
602-604-3563. Their employee
benefit group can provide assistance
to larger employers who need help
identifying which components of their
health plans are subject to this fee, or
determining the best method to assess
the annual number of lives covered.
As a member benefit, AAIA will be
presenting a series of webinars on this
topic, beginning on Sept. 18. For more
information, contact Susan Medick,
AAIA, at susan.medick@aftermarket.
org, or call 301-654-6664.
Anita F. Baker, CPA, CEBS is a partner with
CliftonLarsonAllen LLP, a national accounting
and consulting firm with 90 offices across the
country. Based in Arizona, Baker leads the
firm’s employee benefit plan practice group.
CliftonLarsonAllen is the second-largest auditor
of employee benefit plans in the U.S. and
provides services to over 2500 plan sponsors.
When using the lookback method, employers
may elect to add an
administrative period
up to 90 days between
the measurement
period and the stability
period. It will be
important to measure
full-time employees in
2014 to avoid the ACA
penalties in 2015.
• Ongoing Employees: Employers
may set a standard measurement
AFTERMARKET INSIDER | VOLUME 83 | 3
http://www.aftermarket.org/healthcare
Table of Contents for the Digital Edition of Aftermarket Insider Issue 83
Health Care Help:industry News
Millennials:The Aftermarket Generation
Talking Telematics:INSIDE TECHNOLOGY
Dress for Success
Workplace Wear:TOOLBOX
Conflict Minerals
Facts and Feedback:MARKET INTELLIGENCE
Words from a Winner:HEAD OF THE CLASS
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