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Guidance on Full-Time Employees, W-2 Safe Harbor, and 90-Day Waiting Period

The following information has been provied by Dennis Spingola of Cottrill Arbutina Benefit Solutions Group:

New guidance has been issued to help employers:

  1. determine who is a full-time employee for purposes of the employer mandate,
  2. determine whether coverage is affordable for purposes of the employer mandate, and
  3. comply with the 90-day waiting period provision of the reform.

These provisions will become effective beginning in 2014. The guidance was issued in the form of two Notices and, with respect to full-time employees, introduces several new terms that employers will need to become familiar with, such as “standard measurement periods,” “stability periods,” administrative periods,” and “initial measurement periods.”

The guidance offers safe harbor methods for employers to determine full-time status for ongoing employees, new variable hour employees and new seasonal employees, a safe harbor allowing employers to use employees’ W-2s, rather than household income to determine affordability, and information on how the 90-day waiting period is affected by various types of eligibility conditions. Click below to read more about these complex rules.

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