Reference Guide: Employer Mandate Revisions

 

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What time frame is used to determine the size of an employer? To determine the size of an employer, refer to a consecutive 12 month period To determine the size of an employer, refer to a consecutive 6 month period
When will an employer be subject to the compliance of the employer mandate? All mid and large size employers must comply to the employer mandate by January 1, 2015. An employer will be subject to the employer mandate, given the final revisions, at the time their plan year begins in 2015 for large employers and 2016 for mid-size employers.
What methods are allowed to determine affordable healthcare coverage? Safe harbors permit employers to use W-2 forms, hourly wages, and the poverty line to determine affordability Previous methods remain, however, as clarification, full W-2 wages must be used, which include any employee salary reductions contributed to 401(k) or cafeteria plans.
How do employers determine full-time employee eligibilty? A full-time, eligible employee is anyone who works at least 30 hours per week in the previous year. Previous methods remain, however, clarification revisions were made. Volunteer workers, seasonal workers, and students in work-study programs are NOT considered full-time. Adjunct faculty must be credited 21/4 hours per week for each hour of teaching and 1 hour per week for each additional hour of out-of-classroom work to determine status. No other revisions were made addressing short term employees or those in high-turnover positions.
In the case of a rehire, how does coverage apply? If you rehire an employee to work full-time, they must be offered coverage within 90 days of hire. If the rehire is to work variable hours and their return is within 26 weeks of their departure, the employer must offer coverage within 90 days and continue to cover the employee until the end of the standard plan year. However, they will also immediately start on a new employee measurement period, which if not satisfied by the time open enrollment ends for the next plan year, the employer does NOT need to extend coverage for that year. All previous requirement remain, EXCEPT, if the rehire is to work variable hours and their return is within 13 weeks of their departure, the employer must offer coverage within 90 days and continue to cover the employee until the end of the standard plan year.

 

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