Q.- We have a part-time employee who seems to have averaged working more than 130 hours a month during our plan’s ACA measurement period. Do we really have to offer him health coverage? That doesn’t seem right because we hired him as a part timer.
A.- If you are an applicable large employer (more than 50 employees) and if your plan uses the look-back measurement method, you must apply the results during the measurement period to the upcoming stability period. If the part-time employee really did work an average of 130 hours per month during your measurement period, he will be considered full-time for your upcoming plan year. This means you do have to offer him health coverage in order to comply with the Affordable Care Act. He doesn’t have to enroll in the coverage, but you do have to offer it to him.