For ACA purposes, full-time and part-time should be established by the employer at time of hire for any new employee.
A Full Time “FT” employee is an individual who when hired, was hired into a position which is clearly known in advance the individual will be employed for at least 30 hours per week. For a “FT” employee, the employer has no need (or desire) to track hours because this individual is clearly full time. Examples of a “FT” employee may include management, office staff, operations staff, etc. These employee must be offered health insurance benefits after a standard waiting period – typically 30 or 60 or 90 days (90 days is the maximum period allowed by ACA).
A Part Time “PT” employee is an individual whose schedule cannot be definitively known in advance. In other words, the employee’s hours vary such that it is not possible to determine in advance whether the employee will work 30 weekly hours or more during their period of employment. An employer will typically track or monitor hours for these individuals to determine if they must be offered health benefits. Another name for a “PT” is “Variable Hour”. For “PT” employees, ACA allows an employer to use a measurement period (3-12 months in length) to calculate hours and determine if the individual must be offered benefits at the conclusion of the measurement period.
Factors that may apply in identifying variable hour employees include whether:
- The employee is replacing a full- or part-time employee
- Employees in the same or similar positions are full- or part-time employees
- The job was advertised or otherwise represented as requiring 30 hours or more per week
- The employer presently tracks / monitors hours to determine benefit eligibility
For purposes of the Nimble Reporting ACA dashboard, only employees coded as “PT” will be tracked and calculated into the appropriate measurement periods. The dashboard does all the background work – it calculates hours and informs the employer who should be offered health benefits based on the employer’s measurement period criteria.
Importantly, the employer must not identify a “PT” as “FT” solely because the individual may have averaged >30 hours per week in a prior period – in other words, an employee must continue to be classified in the payroll system as “PT” (unless the job responsibilities / position has changed to that of a “FT” employee) to ensure the dashboard continues to apply measurement periods to these employees at all times.