The Patient Protection and Affordable Care Act's Employer Shared Responsibility provisions specify that “variable hour” employees who average 30 hours per week during a set measurement period should be offered coverage. The measurement periods can vary based on how the employer sets them, which could result in employees becoming eligible for coverage at different times during the plan year and after the maximum 90-day, new-hire waiting period. Employees could become eligible for coverage as much as 13 months after their date of hire.
Employees can be added to the HAP plan at any time based on the employer’s eligibility determination.
Starting in 2014, the PPACA requires that individuals have minimum essential health coverage for each month of the year, qualify for an exemption, or pay a federal income tax penalty. As a result, employees who have previously waived coverage may seek to enroll in the employer group plan on January 1, 2014. If the employer’s open enrollment and renewal occur on a different date (non-calendar-year), employers are allowed to permit a one-time coverage election during the plan year, even though it is not considered a qualifying event.
HAP will work with employer groups who have a non-calendar year renewal and those employees electing coverage for January 1, 2014.
