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Employer Mandate Rules and Seasonal Workers After 2015

Employers face a number of issues when it comes to seasonal workers. The most predominant issue is whether employers are required to provide them with health care coverage in relation to the mandates of the Affordable Care Act (ACA).

Over the last few weeks we have addressed how the seasonal workforce of an organization determines its status as a small or large employer (view here) and who they must offer health care coverage to under the Affordable Care Act (ACA) (view here).

Today we will look at how the employer mandate rules will be different after 2015.

Small to Large Employer

After the transitional year of 2015, if an organization employs an average of 50 full-time employees, including full-time equivalents during the previous year, it will be classified as a “large” employer.  The year to put a plan in place for dealing with seasonal employees is 2015.  What an employer does in 2015 will determine whether it is a large employer in 2016 and whether it must offer health care coverage to its seasonal employees in 2016.

Employers with close to 50 employees should understand the large employer calculations and pay close attention to their staffing needs and employee headcount in 2015 so strategies can be put into place to address the employer mandate in 2016. To determine whether they are subject to the mandate in 2016, employers need to remember that the size of their workforce in 2015 will be the deciding factor in most instances.

The measurement period that an employer uses to determine full-time status of employees in 2015 will determine whether the employee is a full-time employee in 2016 and if they must be offered health coverage.  If an employer’s status is clearly large, they should adopt the appropriate measurement period and manage the hours of their seasonal employees during 2015.  By doing this, the seasonal employees are not considered full-time employees for their 2015 look back period.

To learn more about these strategies and how they can be developed for your organization, please feel free to contact us. After all, experts like Paypro are navigating the difficult legal landscape every single day, and can provide trusted guidance and insights that keep organizations like yours compliant and focused on what they do best.

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