using the look back measurement method · using the look back measurement method may 13th , 2015...

Using the Look Back

Measurement

Method

May 13th , 2015

Lisa Klinger, J.D.

5/13/2015 1

Agenda Purpose of this webinar is to help YOU implement the Look-

Back Measurement Method

Overview of 4 steps to compliance with Employer Mandate

Overview of Look-Back measurement Method

Applying it to various examples

Change in employment status

Counting hours during a break in service

5/13/2015 2

3

Determine Employer Size Determine Compliance

Date

Determine What will be

Offered

Determine Which

Employees will be

Offered Coverage and

When

Step 1 Step 2 Step 3 Step 4

JOEY – CHANGE TO OUR COLORS: Employer Shared Responsibility

4 Steps to Compliance with

Employer Mandate Compliance

5/13/2015

What do you Need to Determine?

As of what date does Employer Mandate apply?

To which categories of employees will Look-Back method

apply?

Set Standard Periods -Stability, Administrative, Measurement

Use payroll records to track hours during Measurement Period

Which particular employees’ hours will be tracked during most

recent Look-Back period?

Set Initial Periods -Stability, Administrative, Measurement

Track new hires’ hours in both Initial & Standard Measurement

Periods

5/13/2015 4

Why do Employers Need a

Measurement Method?

Employer mandate – Large employers

To Determine who is Full-Time

When eligible for coverage

Calculation of penalty amount

Two Measurement Methods:

Monthly

Look-back

5/13/2015 5

Which Measurement Method to Use?

General Rule

Must use either Look-back Measurement Method OR Monthly

Measurement Method for all employees in the same category

Allowable Categories

Salaried employees vs hourly employees

Collectively bargained vs non-collectively bargained

Each group of collectively bargained employees covered

by a separate collective bargaining agreement

State that is employee’s primary places of employment

5/13/2015 6

Exception for Full-time New Hires

EXCEPTION to the General Rule

For newly hired FT employees, (expected at DOH to

work full-time), employer must track hours each calendar

month and offer coverage by first day of 4th calendar

month.

Must continue to track hours monthly until new employee

becomes an “ongoing” employee.

Once new FT employee becomes an ongoing employee,

then track under method that applies to that category

“Ongoing” employee has completed one Standard

Measurement Period

5/13/2015 7

When Can the look-Back Method Apply?

Category of Employee OK to Use Look-Back Method?

Newly hired, reasonably expected

at date of hire to be full-time

No

Ongoing full-time employee Yes, but often not for salaried

Ongoing variable hour employee Yes

Newly hired variable hour

employee

Yes

Seasonal employee, new or

ongoing

Yes

Newly hired temporary employee

expected to work full-time only

for limited number of months

No

5/13/2015 8

Overview of Look-Back Method

Measurement Period

Administrative Period

Stability Period

5/13/2015 9

Measurement Period Admin

Period Stability Period

Overview of the Look-Back Method

Measurement Period • Track employees’hours during the Measurement Period

• Full-Time= 780 hrs/ 6 months; 1,560 hrs/12 months

Administrative Period

• Calculate who was FT in Measurement Period, Notify employees who

were FT, send enrollment materials, give FT employees time to enroll

• Cannot cause a gap in coverage, nor reduce or lengthen MP or SP

Stability Period

• Offer coverage to employees who were full-time in Measurement Period,

regardless of hours actually worked during the Stability Period, but

individual must continue to be an employee

• Must be at least as long as Measurement Period, & minimum 6 months

• Stability period usually starts on first day of your plan year.

5/13/2015 10

Some Frequent Questions

During the Measurement Period, must I count ALL hours

an employee works? Or can I cap it at 40 hours/week?

NO, you cannot cap it. You must count all hours worked.

Do I have to count hours an employee is on leave or

vacation?

YES, all hours of service for which an employee is paid or

entitled to payment. Plus hours of “special unpaid leave”

Do I have to continue to offer benefits to an employee for

the rest of the Stability Period if the employee’s hours

drop and the employee only works part-time?

YES, that’s the point of the Stability Period. Limited

exception, to be discussed later.

5/13/2015 11

Look-Back Method over Four Years Employer with a calendar-year plan selects a 12-month measurement period:

Standard Measurement Period: December1st through the following November 30th

Administrative Period: December 1st through December 31st of same year

Stability Period: January 1st through December 31st of the next year

5/13/2015

Measurement Period

Admin Period

Measurement Period

Dec .1 – Nov. 30

Admin Period

Dec 1-31

Stability Period

Jan. 1 – Dec. 31

Measurement Period

Dec .1 – Nov. 30

Admin Period

Dec 1-31

Stability Period

Jan. 1 – Dec. 31

Measurement Period

Dec .1 – Nov. 30

Admin Period

Dec 1-31

Stability Period

Jan. 1 – Dec. 31

12

Measurement Period

Dec .1 – Nov. 30

Admin Period

Dec 1-31

Stability Period

Jan. 1 – Dec. 31

Two Kinds of Look-Back Methods

Standard Look-Back Method: method for ongoing

employees

Initial Look-Back Method: method for newly-hired

employees

Exception: For newly hired employees who are reasonably

expected to work full-time. must track their hours monthly

initially, even if Look-Back Method applies to that category of

employees.

Until new employees become ongoing employees

Confusion: “Initial” Standard Measurement Period is not the

same as the “Initial” Measurement Period.

5/13/2015 13

Standard and Initial Look-Back Measurement

Methods

Initial Look Back Measurement

Method

Standard Look Back Measurement

Method

5/13/2015 14

Standard and Initial Measurement Methods

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1 Standard Stability period 2015

Initial Stability period 2015

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12-month Standard Measurement Period

12-month Initial Measurement Period

5/13/2015 15

1

Standard Stability 1


Some Frequent Questions

What do you Mean that the “Initial” Standard

Measurement Period is not the same as the “Initial”

Measurement Period?

See next slide

Wouldn’t I want to use a 6-month Measurement

Period if my variable hour employees mostly work

for only 6 months of the year?

See two slides later

5/13/2015 16

Standard Method: Different 1st MPs

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12-month Measurement Period

1

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12-month Measurement Period

2013

2

Standard Stability period 2015


6-mo MP

6-mo MP

5/13/2015 17

When to Start Tracking Hours: Various MPs & APs

Standard Stability period 2015 3 6-mo MP

Six-month Measurement Periods

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6-month Meas.Period

5/13/2015 18

1

Plan Year 2015

1

6-month Meas.Period

6-month Meas.Period

6-month Meas.Period

6-month Stab.Period

6-month Stab.Period

6-month Stab.Period

Help in Setting Standard Periods

1. Standard Stability Period is probably plan year

2. Admin Period ends day before Stability Period begins

Standard Admin period can be 1, 2 or 3 months

3. Meas. Period ends day before Admin Period begins

4. Employees who were there during prior Measurement

Period: count their hours and determine if they are

eligible as of first day of Stability Period

5. Advantages and Disadvantages of 6 & 12 months

6. 780 hours in 6 months or 1,560 hours in 12 months

5/13/2015 19

Examples of Standard Periods

Co. A has calendar year plan

Co. B has April 1 plan year

Co. C has July 1 plan year

Co. D has September 1 plan year

5/13/2015 20

Various Stability & Measurement Periods

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5/13/2015 21

1

1



Standard Stability period 2015 1


Various Stability, Meas. & Admin Periods

Measurement Period Administrative

Period

Stability Period

Dec 1, 2013-Nov 30, 2014 Dec 2014 Jan 1 – Dec 31, 2015

March 1, 2014 – February

28, 2015

March 2015 April 1, 2015 – March 31,

2016

June 1, 2014 – May 31,

2015

June 2015 July 1, 2015– June 30,

2016

Aug 1, 2014 – July 31,

2015

Aug 2015 Sept 1, 2015 – Aug 31,

2016

5/13/2015 22

6 Month Meas. Periods in 2014

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5/13/2015 23

2


Standard Stability period 2015 1

6-month Meas.Period

6-month Meas.Period

How to Use the VH MP & AP Calc

Examples using the VH MP & AP Calculator

5/13/2015 24

Help in Setting Initial Periods

1. Stability Period is same length as Standard Stability

Period, but ER does not set start date

2. Admin Period ends day before Stability Period begins Length of combined Initial Measurement + Administrative

Periods cannot exceed 13 months + a partial month.

Can have “split” Administrative Period

3. Meas. Period ends day before Admin Period begins Starting date varies depending on employee’s hire date

Initial Measurement Period can start on hire date or first of

next month E.g., Hire date Aug 13: Meas. Period can start Aug13 or Sept. 1

Same Measurement Period for all employees in same

category (same 4 categories as noted earlier)

5/13/2015 25

Limit on Length of Initial

Admin. & Measurement Periods

13 months. Initial Measurement Period and

Administrative Period combined may not extend beyond

the last day of the first calendar month beginning on or

after the one-year anniversary of the employee’s start

date (totaling, at most, 13 months and a fraction of a

month).

Example: Employee hired Feb. 13, 2015: Feb 13-28, 2015 = Part 1 of Initial Administrative Period

March 1, 2015 – Feb 29, 2016 = Maximum Measurement

Period

March 1-31, 2016 = Part 2 of Administrative Period

April 1, 2016 – March 31, 2017 = Stability Period

5/13/2015 26

Maximum Length of Initial Meas.+Admin

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5/13/2015 27

1 1

/

2

Initial Measurement Period and Administrative

Period combined cannot exceed 13 months +

partial month

Example: Using Both Initial &

Standard Methods

As new hire transitions to ongoing employee, employer

will track employee’s hours in both Initial and Standard

Measurement Periods

E.g., Brett is hired as a VH EE in Feb. 2015, so Initial

Measurement Period starts March 1, 2015.

Standard Measurement Period for all current employees

starts December 1, 2015, so employer also starts

tracking Brett’s hours December 1

5/13/2015 28

Using both Initial & Standard Methods

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5/13/2015 29

1

1


Standard

Stability

1

/

2

Brett

hired

Brett becomes

ongoing EE

Measurement Methods

Newly Hired Employee

Reasonably Expected to be

Full-time

Newly Hired Employee not

Expected to be Full-time (and full-time employees who meet seasonal

definition) Ongoing Employee

Track Hours Monthly (even if

Look-Back Method Applies)

Initial Look-Back Measurement

Method

Standard Look-Back Measurement Method

Example where Employer Selects Look-Back Measurement Method for All Categories of Employees

Considerations

To which categories of employees will Look-Back method

apply?

To which particular employees will Look-Back method apply?

Set Standard Stability Period - probably Plan Year

Set Standard Administrative Period - 1, 2 or 3 months

Set Standard Measurement Period - probably 6 or 12 months

Use payroll records to track hours during Measurement Period

What is date Employer Mandate first applies to this employer?

5/13/2015 31

Considerations – continued Waiting Period rules also apply

Ongoing employees will be eligible as of first date Employer

Mandate applies (e.g., January 1, 2015) – if they met waiting

period requirement prior to that date

Set Initial Stability Period - same length as Standard

Set Initial Administrative Period - limit on Admin + Meas

Set Initial Measurement Period - probably 6 or 12 months

Will payroll system track hours and generate reports on individual

employees?

Track new hires’ hours in both Initial & Standard Measurement

Periods

5/13/2015 32

Changes in Employment

Circumstances

33

What If Employment

Circumstances Change?

Change in hours or employment status

Under Look-back or Monthly Measurement Method?

In Initial or Standard Measurement Period?

In Stability Period?

Periods for which employee has no hours of service

Upon rehire, is employee a new-hire or an ongoing

employee?

13-week rule

Rule of Parity

26-week rule for educational institutions

If on-going, do any hours count during the break?

5/13/2015 34

Change from PT, VH or Seasonal

To FT

During Initial Measurement

Period (New-Hire, using

Look-Back method) or

-Anytime using Monthly

method

Offer coverage by the earlier of:

--1st day of the 4th month after

the date the EE changes to an

eligible (FT) category, or

--1st day of the associated

stability period if EE was FT in

Initial Measurement Period

During Standard

Measurement Period, which

is also the Standard Stability

Period associated with the

prior Measurement Period

(under Look-Back method)

Change will not affect the

employee’s classification as a

FT employee (or not FT

employee) for the remainder of

the Stability Period.

--But in practice, employer is

likely to offer benefits.

5/13/2015 35

Look-Back Method over Four Years Employer with a calendar-year plan selects a 12-month measurement period:

Standard Measurement Period: December1st through the following November 30th

Administrative Period: December 1st through December 31st of same year

Stability Period: January 1st through December 31st of the next year

5/13/2015

Measurement Period

Admin Period

Measurement Period

Dec .1 – Nov. 30

Admin Period

Dec 1-31

Stability Period

Jan. 1 – Dec. 31

Measurement Period

Dec .1 – Nov. 30

Admin Period

Dec 1-31

Stability Period

Jan. 1 – Dec. 31

Measurement Period

Dec .1 – Nov. 30

Admin Period

Dec 1-31

Stability Period

Jan. 1 – Dec. 31

36

Measurement Period

Dec .1 – Nov. 30

Admin Period

Dec 1-31

Stability Period

Jan. 1 – Dec. 31

Change from FT

To PT, VH or Seasonal

During Initial

Measurement Period

(New-Hire, using Look-

Back method)

or anytime using Monthly

method

Hours are tracked monthly

for a new-hire who is

reasonably expected at date

of hire to work FT, even if

Look-Back method would

generally apply.

So, can drop employee’s

coverage in the month (s)he

changes to PT, if works

fewer than 130 hours that

month.

But must offer COBRA 5/13/2015 37

Change from FT

To PT, VH or Seasonal

After Initial Measurement

Period, which would be:

-in Initial Stability period,

-in Standard Measurement

period,

-in Standard Stability

period,

-in Administrative period


-In Stability period: EE would

continue to have coverage or not,

based on hours worked during

associated Measurement period.

-In Standard Measurement period:

ER would continue to track EE’s

hours, and total hours in

Measurement period would

determine eligibility during the

next Stability period.

--But Special Rule, exception to

general rule. See next slide.

5/13/2015 38

Change from FT To PT, VH or Seasonal

Special Rule

During Stability period,


Applies if EE changes to a

different position and goes

from FT to PT.

Disagreement whether it

applies even if EE only

changes from FT to PT but

remains in some position.

-Special Rule: “(f)(2) rule”

-ER can begin to apply the monthly

measurement method as of the 1st

day of the 4th calendar month

after change in employment

status, but only if:

1- The ER offered this EE MV

coverage from at least 1st day of

4th month of employment through

end of month change occurs, and

2- During each of 1st 3 full

calendar months following change

in status, EE averaged < 30 hrs/wk

5/13/2015 39

Hours During Leaves & Periods

of Non-Service

40

Periods during which EE has No

Hours of Service

Periods for which employee has no hours of service

Upon rehire, is employee a new-hire or an ongoing

employee?

13-week rule

Rule of Parity

26-week rule for educational institutions

If on-going, do any hours count during the break?

5/13/2015 41

13-Week Rule

If an employee has no hours of service for less than 13

weeks: When the employee returns to work, treat employee as an

ONGOING employee

Count hours before the break and during the break to

determine if employee is FT or not during the

Measurement Period

If an employee has no hours of service for 13 weeks or

more: When the employee returns to work, treat employee as an

NEW employee

The employee has a new Initial Measurement period

which begins on new date of hire. Count only hours after

the break..

5/13/2015 42

Rule of Parity

If an employee has no hours of service for less than 4

weeks: When the employee returns to work, treat employee as a

CONTINUING employee and count hours before the break

If an employee has no hours of service for 13 weeks or

more: When the employee returns to work, treat employee as an

ONGOING employee - new Initial Measurement period.

If employee has no hours of service for 4-13 weeks: Compare length of leave to length of prior employment time:

Leave > prior employment: new hire

Leave < prior employment: ongoing EE, count hours

5/13/2015 43

Hours to Count for Employees on

Leave and for Re-Hires

Types of Leave or Non-Service Count Hours to Determine Status?

Hours during Paid Leave Count as regular hours

Hours during “Special Unpaid Leave” --FMLA, USERRA, unpaid jury duty

Count as regular hours

Other unpaid leave or non-service:

• Leave for more than 13 consecutive weeks

Treat as terminated and rehire as a new employee

• Leave for less than 13 consecutive weeks

Option #1: Treat as a continuing EE, & count hours before & after leave, OR

• Rule of Parity: Leave = 4 - 13 weeks Leave > prior employment: new hire Leave < prior employment: count hours

• Rule of Parity: Leave = less than 4 weeks

Count hours before & after leave

5/13/2015 44

JAN FEB MAR APRL MAY JUNE JULY AUG SEP OCT NOV DEC

Work Gone Gone Work Work Work

Rule of Parity: Example #1

Example 1: Employee works 5 weeks, no work next two

months (8 weeks), then is rehired. Upon return to work:

--Can treat employee as a new employee, so

--hours worked prior to the break would not have to be

counted in determining FT – PT status during the Look-

Back Measurement Period.

5/13/2015 45

---------Count hours in April, May & June

Rule of Parity: Example #2

Example 2: Employee works three months, terminates

and is rehired 2 months later. Upon return to work:

--Treat employee as a ongoing employee,

--Hours worked prior to break must be counted in

determining FT – PT status during the Look-Back

Measurement Period.

----------Count all hours in MP

5/13/2015 46


Work Work Work Gone Gone Work


Work Work Gone Work Work Work Work Gone Gone Work Work Work

Bens No No Bens Bens Bens

Treatment of Continuing Employee

For “ongoing employee” (as opposed to “terminated and rehired”):

Measurement and Stability periods that would have applied

As if employee did not have the period with no hours of service

Example: Employee returns to work during a Stability Period in which the

employee would be treated as a full-time employee (based on hours worked

during associated Measurement Period):

Employee must be treated as full-time through end of stability period

And enrolled in medical benefits as soon as possible, 1st of next

month

-----Measurement Period Jan-June----- // ----Stability Period July – Dec----

-------Count all hours in MP

5/13/2015 47

Document Your Measurement

Methods and Periods

Have a separate written policy and add language to your

handbook, SPD, enrollment materials, plan document

At least: notify employees that eligibility will be determined

using Measurement Methods under the Affordable Care Act

Better: Specify which categories of employees will be

tracked under which Measurement Method

Define Variable Hour Employee and Seasonal Employee

Eligible and ineligible classes for health benefits coverage

Short explanation of Measurement and Stability Periods,

when hours will be tracked and when employees will be

eligible for coverage

48 5/13/2015

Guidance on Final Regs 2/10/14

Final Rule (227 pages):

https://s3.amazonaws.com/public-

inspection.federalregister.gov/2014-03082.pdf

IRS Fact Sheet (3 pages):

http://www.treasury.gov/press-center/press-

releases/Documents/Fact%20Sheet%20021014.pdf

IRS Qs & As (15 pages):

http://www.irs.gov/uac/Newsroom/Questions-and-

Answers-on-Employer-Shared-Responsibility-Provisions-

Under-the-Affordable-Care-Act

5/13/2015 49

https://s3.amazonaws.com/public-inspection.federalregister.gov/2014-03082.pdf






http://www.treasury.gov/press-center/press-releases/Documents/Fact Sheet 021014.pdf





http://www.irs.gov/uac/Newsroom/Questions-and-Answers-on-Employer-Shared-Responsibility-Provisions-Under-the-Affordable-Care-Act

























Thank You!

QUESTIONS?

DISCLAIMER:

This presentation is intended for general

informational purposes only and does not

constitute legal advice.

Consult with your legal counsel to discuss how

laws discussed in this presentation apply to your

specific circumstances and affect your obligations.

5/13/2015 50

Additional Slides

Not part of the regular presentation

5/13/2015 51

Overview of Large ER Mandate

5/13/2015

ALE may be subject to excise tax if at least 1 FT EE with household income 100-400% of FPL buys coverage in Exchange and gets a tax credit, and employer either:

Does not offer MEC to FT EEs and their dependents

Penalty = $2000/yr x (FT EEs – 30)

- 70%/95% and 80/30

- MEC definition

-Dependent cvrg

Offers coverage to FT EEs and dependents, but it is not affordable

or does not provide MV

Penalty = $3000/yr for each affected FT EE

- “Affordable”

- “Minimum Value”

52

Which Employees are Full-time?

At least 30 “hours of service”/week or 130/month “Hours of Service,” not hours worked

How to count time during leaves and breaks in service

Which employees are full-time and when?

Are you offering coverage to 70% of FT EEs (95% in

2016)?

5/13/2015 53

Full-time Employees: Hourly

Hours counted to determine full-time status include both:

Hours when work is performed, and

Hours for which an employee is paid or entitled to payment

even when no work is performed: vacation, holidays, illness,

disability, layoff, jury duty, military duty or leave of absence

But not if employee is paid by a third party

5/13/2015 54

Full-time Employees: Non-Hourly

Alternative methods to determine full-time status of non-

hourly employees:

Actual hours of service

Days-worked equivalency method – 8 hours if > 1 hour

Weeks-worked equivalency method – 40 hours if > 1 hour

Cannot use a method that would understate employee’s

actual hours and count a full-time employee as part-time

5/13/2015 55

Special Categories of Employees

Adjunct Faculty Members - 2 ¼ hours/hour of classroom

time + actual hours outside of class

School employees – full-time even if no hours during

school break periods

On-call employees – reasonable method

Employees on Layovers - reasonable method

Bona fide volunteers – are not employees

Real estate agents & Direct sellers – are not employees

Home care workers – are employees of recipient

employer

5/13/2015 56

Standard Look-Back Method:

Stability Period Offer coverage to employees who were full-time during

the Standard Measurement Period

Set starting date as of first day of Plan Year

Length is generally the same as the Measurement Period

For full-time employees during Measurement Period: must be at least six consecutive calendar months, and

cannot be shorter than the Measurement Period

E.g., can’t have 12 month Measurement Period & 6

month Stability

For part-time employees during Measurement Period: may not be longer than the Standard Measurement Period

5/13/2015 57

Another Way to Show How the Look-Back

Method Works

5/13/2015

Meas Per 2 Meas Per 3 Meas Per 5

Stability Per 1 Stability Per 2 Stability Per 3

Meas Per 4

Stability Per 4

Dec 1–Nov 30 Dec 1–Nov 30 Dec 1–Nov 30 Dec 1–Nov 30 Dec 1–Nov 30

Stablty Per 1 Jan 1-Dec 31

Stablty Per 2 Jan 1– Dec 31



Admin Period

= Dec 1-Dec 31

Meas Per 1

Calendar year plan, 12-month MP & SP, 1-month AP

* During Measurement Period (MP): track employees’ hours.

58