Part-time and variable-hour employees are most exposed to marketplace prices.
Employees you do not offer coverage to usually end up on the individual market, and 2027 prices there are higher. KFF estimates about 13% for HealthCare.gov. Expect more questions about hours, eligibility and waiting periods.
Your answers depend on how you define full-time and how you track hours, and both are set by federal rules. Send us your renewal and we will give you a second opinion in writing.
Three things to have in order before the questions arrive.
Who counts as full-time
For the employer mandate, a full-time employee averages at least 30 hours of service a week, or 130 hours in a month (IRC §4980H(c)(4)). Offering coverage to those employees is what the mandate measures.
Variable-hour tracking
Employers with variable-hour or seasonal staff can use a look-back measurement method to decide who is full-time, with a measurement period, an administrative period and a stability period (26 CFR §54.4980H-3). Check that your method is written down and applied the same way each year.
Waiting periods
A group health plan cannot impose a waiting period longer than 90 days (45 CFR §147.116). New hires who ask about marketplace coverage while they wait should be told the date coverage starts.
Keep reading.
HealthCare.gov premiums rise again in 2027
What the 2027 marketplace increases mean for an employer plan. Back to the marketplace page.
Keep reading on 2027 marketplace premiums.
Where these figures and rules come from.
Figures and rules
Full-time employee definition: IRC §4980H(c)(4). Look-back measurement method: 26 CFR §54.4980H-3. Waiting-period limit: 45 CFR §147.116. KFF and The Hill: KFF estimates about 13% for HealthCare.gov in 2027, as reported by The Hill on October 31, 2026; KFF’s review of insurer filings found a median proposed increase of 15% (KFF, How Much and Why ACA Marketplace Premiums Are Going Up in 2027). This page is general information, not legal or tax advice.
Send us your renewal.
Four documents — the renewal letter, the plan summary, the contribution split by tier and enrolled counts by tier. We’ll come back with a competitive read, where we see opportunity, and the five questions we’d put to your carrier.
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