Changing An Employee Job Or Hours Changes How The Benefit Plan Sees Them.
Reassignment to a vacant position and part-time or modified schedules are accommodations the ADA names. Either can push an employee across a plan eligibility line or an ACA full-time measure, so look at the benefit effects before agreeing.
When Job Changes Are An Accommodation.
Informational only, not legal advice. Check what the rules say now.
Reassignment To A Vacant Position
When an employee cannot do the current job even with accommodation, reassignment to a vacant position they are qualified for can be required, as a last resort.
Modified Or Part-Time Schedules
Changing start times, adding breaks or reducing hours can be a reasonable accommodation when the essential functions can still be done.
No Pay Or Benefit Penalty
The employee is treated like others in the new position for pay and benefits, but the employer is not required to raise pay above that of the new role.
Understanding The Benefit Effects.
A reduced schedule is easy to grant in operations and hard to follow in benefits. If the plan requires 30 hours a week for eligibility, a reduction to 24 hours can end coverage, which triggers COBRA and may leave the employee without health insurance at the time they most need it.
Under the ACA employer shared responsibility rules, an employee is full-time at 30 hours a week or 130 hours a month. An employer using a look-back method may keep an employee in full-time status through a stability period, and fewer hours do not by themselves end that status. The plan terms should say which method is used.
Reassignment can change the benefit class, contribution amounts and eligibility waiting periods. Put the new terms in writing, confirm them with the carrier or administrator and keep the accommodation file separate from benefit enrollment data.
Where this shows up in your plan.
Plan Eligibility Hours
Check the plan hours threshold before agreeing to a schedule that falls below it, and discuss alternatives with the employee.
ACA Full-Time Measurement
Look-back measurement rules affect whether a reduced-hours employee remains full-time for the employer mandate during the stability period.
Benefit Class On Reassignment
A new position may belong to a different benefit class with different contributions, waiting periods and eligibility.
Setting it up.
Identify the effect of the schedule or role change on plan eligibility and ACA status.
Review the plan document and the full-time measurement method in use.
Discuss the benefit consequences with the employee before the change takes effect.
Document the agreement, the new terms and any review date.
Tell the carrier or administrator about eligibility changes, and prepare COBRA notices if coverage will end.
Mistakes to avoid.
Granting a reduced schedule without checking the plan eligibility threshold.
Treating a 30-hour week as automatically eligible without reading the plan.
Letting a reassigned employee fall into a waiting period without notice.
Mixing benefit data with the accommodation file.
Other rules employers work with.
Accommodation Hub: Reassignment and Reduced Hours
See the general accommodation overview.
Salary Thresholds Under the FLSA and Plan Eligibility
Where hours worked and pay affect who is eligible.
ACA Compliance For Employers
Basics that apply to any business.
Laws and Rules Referenced
Definitions, including reassignment and modified schedules, 42 U.S.C. 12111 — Examples of reasonable accommodation.
ADA regulation on accommodation, 29 CFR 1630.2 — Reasonable accommodation in detail.
Shared responsibility for employers, 26 U.S.C. 4980H — Full-time employee definition and the ACA employer mandate.
Reasonable accommodation guidance from the EEOC — Reassignment and modified schedules.
Quick answers.
Short replies on reassignment, reduced hours and benefit eligibility, linked to the full guide.
Is reassignment always required?
No. It is an accommodation of last resort, for a vacant position the employee is qualified for, when no accommodation in the current job works.
Can reduced hours cost the employee health coverage?
Yes, if the hours drop below the plan’s eligibility threshold or its measurement rules, so read the plan first.
Do we have to raise pay on reassignment?
No. The employee is paid according to the new position.
Does a reduced schedule end full-time ACA status?
Not necessarily. A look-back measurement method can keep the status for the stability period.
More guides in this series.
Reasonable Disability Accommodation Under the ADA for Michigan Employers
A companion guide in the same series.
Religious Accommodation Under Title VII and Michigan Law
A companion guide in the same series.
The ADA Interactive Process for Michigan Employers
A companion guide in the same series.
Disability Leave, Accommodation and Health Plan Eligibility
A companion guide in the same series.
ADA, GINA and Wellness Program Rules for Michigan Employers
A companion guide in the same series.
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