Act Now on ACA Compliance
Large employers are advised to begin analyzing their employee population now to accurately predict the number of full-time employees for which they'll need to provide coverage.
If you're thinking the federal government's recent one-year extension for the Affordable Care Act employer mandate was equivalent to an extended holiday, think again. The extension was granted partly because most employers were not prepared to provide appropriate health coverage offerings to their full-time workforce on January 1. Large employers in particular will be most wise to take steps now to learn the government's definition of full-time employee as it relates specifically to the ACA (it's not the same as "full-time" for overtime pay, etc.) and begin the extensive process of measuring and managing their potential covered population so that by this time next year they are prepared to make informed decisions that benefit themselves and their workforce.
One of the great ironies of the Affordable Care Act is that it was originally proposed as a way to make healthcare coverage more convenient for individuals and employers. Unfortunately, the government's definition of who qualifies as full-time under the ACA can be difficult to decipher and how you go about measuring it is cumbersome at best.
The “measurement period” is the period of not less than three but no more than 12 months where an employer figures out the average hours worked per week by an employee during that time. For example, an employer who establishes a 12-month measurement period averages the employee’s hours over those 52 weeks to see if they are 30 or above (the cutoff for paying a penalty by not offering coverage). The “administrative period,” which cannot exceed 90 days, is the period where you enroll these eligible employees. The “stability period,” which has different lengths of maximum time for new hires versus current employees, defines how long they will have coverage.
The interaction works something like this (assuming a 12-month measurement period and a 90-day administrative period):
- Measurement period 1: Oct. 1, 2013 through Sept. 30, 2014
- Administrative period 1: Oct. 3, 2014 through Dec. 31, 2014
- Stability period 1: Jan. 1, 2015 through Dec. 31, 2015
- Measurement period 2: Oct. 1, 2014 through Sept. 30, 2015
- Administrative period 2: Oct. 3, 2015 through Dec. 31, 2015
- Stability period 2: Jan. 1, 2016 through Dec. 31, 2016
- Measurement period 3: Oct. 1, 2015 through Sept. 30, 2016
- Administrative period 3: Oct. 3, 2016 through Dec. 31, 2016
- Stability period 3: Jan. 1, 2017 through Dec. 31, 2017
Of course, employers can choose their own period lengths (as long as they comply with the law) so not all employers will be the same. A great resource we've found for learning the employer requirements of the ACA employer mandate may be found at this link. Just remember that starting in 2015 employees must always be in a stability period for full compliance, so it’s best not wait until October of next year to start planning. The time has come.