As the end of the summer approaches, Employers should review their seasonal employee hiring. A seasonal employee is an employee who is hired into a position for which the customary annual employment is six months or less. This assumes that by the nature of the position, employment begins and ends approximately the same time each calendar year.
For large employers who use the look-back method to determine full-time status, a seasonal employee is initially treated as a variable hour employee. The seasonal employee does not have to be offered health coverage, but the employee’s hours are counted starting on date of hire.
If the seasonal employee is terminated from employment within the 6 month period, no coverage would have had to be offered. If the seasonal employee remains employed past the seasonal term, the individual’s hours from date of hire are considered in determining if the employee ends up working more than 130 hours per month to be considered a full-time employee in the next stability period.
BAS’ Affordable Care Act data collection and reporting tool can help employers with hours counting and required ACA filings. For more information about BAS’ ACA services, contact your account manager or solutions@BASusa.com.
