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Monday, 09 November 2020 13:38

Furloughs, Leaves of Absences, and Measurement Periods – Oh My!

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This year has been filled with many questions and not so many clear answers. One of the trickiest ACA issues that Applicable Large Employers (ALEs) have to navigate through is how measurement periods apply during furloughs and leaves of absences due to COVID-19. It’s important for ALEs that offer affordable and minimum essential health insurance coverage to be able to identify their full-time employees and offer group health benefits at the appropriate times; otherwise the employer may be subject to costly penalties.

Employers with stable workforces and employees easily defined as full-time or part-time may find this to be an easier task. However, many employers have recently faced new challenges with more variable-hour employees and some that were furloughed or took leaves of absence due to COVID-19.

Guidance in the ACA provides the option of using a system of measurement and stability periods to determine which employees qualify as full-time under the ACA and therefore eligible for benefits. Many employers use 12-month measurement and stability periods to minimize recordkeeping requirements, but this is not a “one size fits all” approach, as the right strategy depends greatly on the employer’s goals.

Check out our Alera Legal Alert for more information about ACA Measurement Periods and how they may apply to your organization, including:

  • Who needs to worry about measurement periods?

  • What is the purpose of the measurement methods?

  • Why would an employer choose one measurement method over the other?

  • When an employee is on an unpaid leave of absence, what happens to their hours under the Look-Back Measurement Method?

  • When may an employer use different measurement methods?

  • How are measurement methods used for variable hour, seasonal, temporary, and part-time employees, or interns?

There may also be additional guidance coming with the updated ACA 1095 reporting instructions, and you may also want to consider contacting your legal counsel for a formal opinion. In the meantime, please contact your Fall River Client Manager if you have general questions. 

Read 579 times Last modified on Tuesday, 17 November 2020 14:29
Juliet Fitzgibbons

Juliet joins Fall River as an Account Executive and brings over 15 years of prior broker and account management experience. Her experience brings extensive knowledge on employee benefit programs, account management and creative cost-saving strategies and compliance solutions for employers of various sizes.

She is responsible for new business proposals, client renewals including plan benchmarking, rate analysis and mid-year reviews. She helps clients navigate healthcare systems and educates employers and employees through open enrollment meetings and day-to-day service requests. Juliet joined Fall River in 2015.