Measurement Methods for Identifying Full-time Employees for ACA Purposes

One of the most important parts in ACA compliance is identifying which full-time employees to whom you’re required to make offers of health care coverage. First things first, however, you’ll need to determine if you’re an Applicable Large Employer (ALE). In other words, determine if you have 50 or more full-time employees. And keep in mind that the IRS considers 30+ hours a week (or 130 or more hours/month) to be full-time.

There are two methods for determining full-time employee status:

• The monthly measurement method
• The employer looks at each month the employee has worked individually to see which ones exceeded 130 hours of service
• The look-back measurement method
• The employee goes through a standard measurement period, where they work their usual hours as determined by the employee and employer upon hire.
• Then, the employer determines the employee’s full-time status based on the measurement period, during what is known as a stability period.
• Employers may not use the look-back method when determining ALE status, only for an individual employee’s full-time status.

When determining an employee’s status, an hour of service is considered to be each hour the employee is paid (or should be paid) for performing his/her duties as set by the employer, including the hours the employee is entitled to payment during which no duties are performed (like vacation pay, holiday pay, sick leave, disability, layoff period, jury duty, military duty, or leave of absence). For the purpose of the employer shared responsibility provisions, this does not include these hours of service/employees:

• Volunteer employees
• Students performing work-study
• Members of religious orders
• Compensation that isn’t US source income

You can find more information about totalling hours of employees in more nuanced categories, like adjunct faculty, those who work layover hours (like airline industry employees), and on-call employees, here.

If you have any questions regarding your ACA filing, you can give us a call at the ExpressIRSForms headquarters in Rock Hill, SC. We’re available by phone Monday-Friday, 9:00 a.m. to 6:00 p.m. EDT at (704) 684-4751, and we also offer 24/7 email assistance at support@ExpressIRSForms.com.




Looking for something a little less hands on? Check out ExpressACAForms, our full-service ACA e-filing option.