Total the hours, classify each employee, notify and enroll them inside the administrative period, and keep prior-period coverage running meanwhile.
Compute each employee’s average, compare it with 30 hours a week, and record the result.
Tell employees found full-time that coverage is available, and give any notices your plan requires.
Process enrollment before the stability period begins, and keep coverage going for people already covered.
Sources: 26 CFR § 54.4980H-3. General information, not legal advice.
A measurement period ends October 14. HR totals hours by October 31, classifies employees by November 5 and sends notices by November 12. Enrollment runs through December 15.
Everyone is classified and enrolled before January 1, with about 78 days used of the 90 allowed. Employees covered under the prior period stay covered throughout.
Lock the data.
Compute averages.
Send results and offers.
Process elections.
Where it goes wrong. Waiting to start notices until every edge case is resolved.
Keep the waiver. A documented offer supports your position.
The 90-day limit still applies, so escalate delays early.
Employees found full-time, and your plan’s other required notices to participants.
Make the offer as soon as the error is found and document it.
Not required, but they help prove delivery.
Plan-specific questions belong with ERISA counsel, and we will bring them in.
Run the second test for variable-hour hires, then carry the status months forward into Forms 1094-C and 1095-C.
Pull hours for every employee in the window, apply your equivalency method consistently, and apply the special unpaid leave averaging rules where they apply.
Every rule, example and source behind this page, in one place.
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