A promotion to 40 hours does not make an employee found not full-time into a full-time employee until the stability period ends, and a cut to 15 hours does not remove a full-time employee.
The classification from the measurement period governs the stability period, regardless of changes in hours, title or pay.
A full-time employee whose hours fall stays covered through the stability period, which can mean offering coverage to someone working fewer hours.
Specific rules cover moves between methods and between categories. Outside those rules, status does not move mid-period.
Sources: 26 CFR § 54.4980H-3. General information, not legal advice.
A part-time stocker found not full-time for a stability period running January to December is promoted to a 40-hour assistant manager role in May.
For the employer mandate she stays classified as not full-time until December 31, then the next measurement result applies. The employer can still offer her coverage under the plan sooner if its eligibility terms allow.
Record the date of the new role.
Confirm the end date.
See whether the plan allows earlier enrollment.
Apply the next cycle’s result.
Where it goes wrong. Assuming a promotion immediately creates a mandate obligation.
Not without checking the plan terms and the stability period. For the mandate test, status holds, so ending an offer early can expose the employer to a payment.
Their status changes at the end of the stability period, and the next measurement result decides.
An employee not offered coverage may be eligible for subsidies. The employer penalty depends on who was full-time under the measurement result.
Her status holds for the mandate through the stability period.
Your plan terms and any change in eligibility may require one. Ask counsel.
Plan-specific questions belong with ERISA counsel, and we will bring them in.
When an employee moves from a look-back position to a monthly-method position, an employee in a full-time stability period stays full-time through its end.
If you have continuously offered minimum value coverage and an employee moves to a position expected to average under 30 hours, you may move that employee to monthly measurement from the first day of the fourth full month.
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