Under the look-back measurement method, an employee’s full-time status is established during a “standard measurement period,” which can be three to twelve months long. 26 CFR 54.4980H-1(a)(46). An employee is not considered a full-time employee if the employee’s average hours over the standard measurement period remain under 30 hours per week, even if the employee works over 30 hours in a particular week (or over 120 hours in a particular month). 26 CFR 54.4980H-3(d)(1)(i). Provided that the employee’s combined hours over the 3–12 month long measurement period do not average over 30 hours per week, the employee will not be considered a full-time employee.
We are using the “look-back” measurement method under the Affordable Care Act for purposes of determining whether employees are “full-time” for purposes of offering insurance coverage. If we use a one-year “measurement period,” can we average an employee’s hours over the whole year, or do employees need to stay within 30 hours/week or 120 hours/month?
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