HCW Benefits Blog

Healthcare Reform Questions: Definition of Part-Time Employees

[On June 10, 2010 we held a half day conference at the McKimmon Center in Raleigh titled, Healthcare Reform: The Employers' Guide. The following are questions submitted that we were unable to address due to time restriction.]

1.  If we don't currently cover employees who work less than 32 hrs/wk, would it be best to change our definition to 30 hrs/wk, and what timeline should that be done?

Yes, it is recommended that employers change their definition of part-time employees to the 30-hour-per-week standard to avoid unnecessary penalties.  As such, it is also recommended that employers change their definition of full-time employees to reflect someone who works 30 or more hours per week.  Since this is most applicable for 2014 plan years, it is recommended this be done prior to the employer’s renewal date preceding 1/1/2014.

2.  What happens if we don't offer insurance to those "seasonal/part time" employees who work 30 or more hours per week?

Failure to abide by this mandate could result in a monetary fine of up to $2,000.

3.  We are a large employer with over 800 employees.  Do we have to provide health insurance to a temporary employee who works 30 hrs/wk for one year or risk penalty?

If the employee is working 30 hours-per-week for more than 120 days, then the employer must provide coverage or risk penalty.

4.  If an employer is not required to cover part-time employees (which we do not), and if a part-time employee is not covered by a spouse's plan, will that person be eligible to go to the exchange (once it is established) to purchase their insurance? If so, is there, or will there eventually be, any ramification on the employer not offering coverage to part-time employees?

While more guidance is expected on the government-provided exchanges, early indications are that any individual would be allowed to purchase coverage through an exchange if they desire.  Based on household income, the individual may be eligible for premium and cost-share assistance.  As reform law currently exists, there are no ramifications for employers not offering coverage to part-time employees working less than 30 hours-per-week.

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