Q.- We have a calendar year plan and use the lookback method for determining if someone is a full-time employee for ACA purposes. Our open enrollment period is coming up. One of our employees calculated to be full-time during the lookback measurement period, but we know she will be working part-time in 2022. We don’t have to offer her coverage, do we?
A.- If she averaged 130 hours per month during your lookback measurement period, she should be offered health coverage for the 2022 plan year. This is the case even if she is continuing as a part-time employee in 2022. Her actual hours worked during the measurement period, not her status designation, is what determines if she is full-time for ACA purposes and needs to be offered health coverage.