Even with the delay in the application of the shared responsibility/pay or play penalty under health care reform, employers should begin to take stock of their workforce. Part of the analysis will include counting the number of full time employees, as defined under the Affordable Care Act.
Health care reform requires employers with 50 or more employees to provide health coverage to any employee who works on average at least 30 hours per week (130 hours per month), or face a penalty. The penalty was delayed and will not be imposed until 2015.
Many employers base their full-time status categories on something close to a 40 hour work week. Most employers do not have a 30 hour per week standard for designation of full time status. Therefore, employers should begin thinking about how they will capture hours worked on a 30 hour per week threshold.
Employers may use a few methods for determining the number of full time employees they employ. Employers may use a look back measurement period for counting hours of service, a stability period during which coverage is provided, and an administrative period for enrollment. While the complexities of the calculation options are great, employers should at least begin considering how they will calculate hours worked for employees, and what data they will need to begin to collect to be able to designate full time status for health coverage based on a 30 hour work week.
