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EPAYsystems.com
Tuesday, April 8th 12 p.m. CDT
Register Here
Affordable Care Act Webinar:
Achieving Compliance, Containing Costs &
What You Should Be Doing Right Now
EPAYsystems.com 2 |
Employer Mandate – Large Employers Only
o Threshold for “Large Employer” = 50 Full-time Equivalent Employees in prior year
o Full-time employees = 30 hours per week, on average
#FULL-
TIME EMPLOYEE
S
Aggregate # hours worked/
month by part-time
employees up to 120 ________ Divided by
120
#Full-time equivalent
employees
You must count all employees working for any company within the corporate family (as determined by IRS rules)
EPAYsystems.com
PENALTY
THE LESSER OF:
$2,000 x (Total No. of Full-Time Employees – 30)
$3,000 x No. of Full-Time Employees who receive a tax credit or subsidy and purchase coverage through an Exchange
3 |
Inadequate Coverage Penalty
EPAYsystems.com 4 |
Full-Time Employee
• What is a Full-Time Employee?o Those who work, on average,
30 hours per week or 130 hours per month
o Full-time status determined on a monthly basiso Measurement & Stability periods
Measurement period (look-back) could range between 3-12 months Stability period must be at least as long as the look-back period and
can be no shorter than 6 months Administrative Period up to 90 days between the two
To determine who will be eligible, notify them and enroll them
EPAYsystems.com 5 |
• May use different Measurement and Stability Periods for:
Salaried and hourly employees
Employees of different entities
Employees located in different states
Collectively bargained with different collective bargaining agreements
Measurement/Stability Periods
EPAYsystems.com 6 |
• Examples*► Part-time employees► Hourly employees with fluctuating schedules► Seasonal employees
*These are merely examples of individuals that might be considered variable hour new hires. Facts and circumstances may limit an employer’s ability to treat these employees as variable hour new hires.
• NOTE: Expected (short) length of employment can be taken into consideration, but only for 2014
What is a “Variable Hour” Employee?
EPAYsystems.com
Stability Period coverage begins April 1, 2015 (and continues through March 31, 2016)
Variable Hour New Hire – Hire Date February 15, 2014
Measurement Period ends February 14, 2015Administrative Period From February 15 – March 31
Jan. Feb. Mar. Apr. May Jun. Jul. Aug. Sep. Oct. Nov. Dec.
2014 2015 2016
Measurement Period #1 Stability Period #1
Measurement Period #2
Employee switches to ongoing employee measurement period effective October 1, 2014
Stability Period #2
7 |
When Must Variable Hour New Hires be Offered Coverage?
EPAYsystems.com 8 |
Special Rule: Breaks in Service
Length of Break Length of Employment
Result Upon Rehire
More than 26 weeks
N/A Treat employee as new hire (i.e., start new measurement period and disregard prior service)
Less than 26 weeks but more than 4 weeks
Shorter than break
Treat employee as new hire (i.e., start new measurement period and disregard prior service)
Less than 26 weeks but more than 4 weeks
Longer than break
Continue existing measurement period (0 hours counted during break*)ORContinue coverage for remainder of stability period
Less than 4 weeks
N/A Same as above
EPAYsystems.com
• Compare all employees average hours to ACA guidelines to determine total FTE’s
• Will give total Full Time Employees (> 30 hours)
• Will give total Part Time Employees (< 30 hours)
• Total the two to determine total FTE’s
• Could also use alerting to ensure employees not going over 30 hours per week
ACA Dashboard
EPAYsystems.com
Affordable Care Act Webinar:Achieving Compliance, Containing Costs &
What You Should Be Doing Right Now
Tuesday, April 8th 12 p.m.
CDTFeaturing Attorney
Jennifer Kraft, Seyfarth Shaw LLP
Register Now