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404.03 Measuring Full-Time Employees Under the Affordable Care Act

Ankeny Community School District (“District”) sponsors group health insurance in which certain eligible employees are offered health coverage. The Affordable Care Act (“ACA”) provides guidelines for the determination of full-time status, which in turn defines an eligible emaployee for the District to offer health. Under ACA, the definition of a full-time employee includes an employee who works an average of at least 30 hours per week (or 130 hours per month).

The IRS has provided two methods for determining whether an employee is full-time – the monthly measurement method and the look-back measurement method. The District has adopted the look-back measurement method for all District employees.

Under the look-back measurement method, the District uses hours of service credited during a measurement period (also known as a look-back period) to determine an employee’s full-time or part-time status and then applies that determination prospectively during what is known as a stability period.  General guidelines for the look-back measurement method are provided below; note that special rules may apply for situations such as rehired employees, employees on special unpaid leave of absence, employees with an employment break of four consecutive weeks or more, or employees who have a change in status.

Current (Ongoing) Employees

A current employee’s hours will be measured during the following Standard Measurement Period to determine whether he or she qualifies as a full-time employee.

  • Standard Measurement Period: May 1 – April 30
  • The District will adjust the Standard Measurement Period in order to take into account regular payroll periods.

During the Standard Administrative Period set forth below, the District will analyze the number of hours worked during the Standard Measurement Period and offer coverage to those employees who qualify as full-time.

  • Standard Administrative Period: May 1 – June 30

If an employee qualifies as full-time, he or she will be given an opportunity to enroll in and remain on the District’s health coverage for the Standard Stability Period, provided the employee continues to be employed by the District.

  • Standard Stability Period: July 1 – June 30

New Employees
Variable Hours, Seasonal*, and Part-Time Employees
An Initial Measurement Period applies to new variable hour, seasonal and part-time employees (employees who are not expected to work an average of at least 30 hours per week upon  hire or who are seasonal). The Initial Measurement Period will begin on the first day of the month immediately following the first day of employment; however, if an employee begins employment on the first day of the month, that date will be used.

  • Initial Measurement Period: Twelve months beginning on the first day of the month coincident with or immediately following the first day of employment

New variable hour, seasonal and part-time employees will not be offered District health coverage during an Initial Measurement Period. Instead, their hours will be measured during this time to determine if they qualify as full-time. New full-time employees (employees who are expected to work at least 30 hours per week) shall be offered District health coverage, subject to any normal waiting period that applies to obtain District health coverage, but not subject to completion of an Initial Measurement Period.

An Initial Administrative Period immediately follows the Initial Measurement Period and provides the District time to analyze the number of hours worked by each employee during the Initial Measurement Period. Employees who qualify as full-time will be offered health coverage.

  • Initial Administrative Period: Period of One month immediately following the Initial Measurement Period

If an employee qualifies as full-time, he or she will be given an opportunity to enroll in and remain on the District’s health coverage for the employee’s Initial Stability Period, provided the employee continues to be employed by the District.

  • Initial Stability Period: Twelve month period immediately following the Initial Administrative Period

Each new variable hour, seasonal and part-time employee will have one Initial Measurement, Administrative and Stability Period. After that time, an employee will be considered an ongoing employee and the Standard Measurement, Administrative and Stability Periods shall be used. The first Standard Measurement Period will begin on May 1 after an employee’s start date, so the Initial Measurement and Standard Measurement periods will overlap.

New Full-Time Employees

New full-time employees (employees who are expected to work at least 30 hours per week and are not seasonal) shall be offered District health coverage, subject to any normal waiting period that applies to obtain District health coverage, but not subject to completion of an Initial Measurement Period.

For these employees, determination of the employee’s full-time status is based on his or her hours of service during each calendar month. If the employee’s hours of service for the calendar month equal or exceed an average of 30 hours of service per week, the employee is a full-time employee for that calendar month. Once the new full-time employee is employed for at least one complete Standard Measurement Period, an employee will be considered an ongoing employee and the Standard Measurement, Administrative and Stability Periods shall be used.

*Seasonal is defined as:  An employee who is hired into a position for which the customary annual employment is six months or less. The period of employment should begin each calendar year in approximately the same part of the year, such as summer or winter.

Adopted:
August 18, 2014

Reviewed:
November 20, 2019

Revised:
November 20, 2019