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Lookback Process for Variable Hour Employees: Key Guidelines and Timing for New Hires

This document outlines the Lookback Process for Variable Hour Employees from June 1, 2014, through December 31, 2017. It details the Initial Measurement Period, Stability Periods, and Administrative Periods for new and ongoing employees. Key concepts include the significance of measurement periods and waiting periods that affect employees' coverage eligibility. Employers must take special care when calculating these periods to ensure compliance and continued coverage. Guidelines adapt based on the employee's start date, ensuring proper benefit alignment.

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Lookback Process for Variable Hour Employees: Key Guidelines and Timing for New Hires

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  1. Lookback Process for Variable Hour Employees NEW EMPLOYEE* 6-1-15- 6-30-15 7-1-15 6-30-16 6-1-14 5-31-15 ----Dates Vary With Every New employee--- Initial Measurement Period Stability Period AP (12 Months) • (1 Month) (12 Months) ONGOING EMPLOYEE 10-1-14- 12-31-14 10-1-13 9-30-14 1-1-15 12-31-15 Standard Measurement Period- #1 Admin Period Stability Period #1 • (3 Months) (12 Months) (12 Months) 10-1-15- 12-31-15 10-1-14 9-30-15 1-1-16 12-31-16 Stability Period #2 Admin Period Standard Measurement Period- #2 (12 Months) (12 Months) • (3 Months) 10-1-16- 12-31-16 10-1-15 9-30-16 1-1-17 12-31-17 Standard Measurement Period- #3 Admin Period Stability Period #3 (12 Months) • (3 Months) (12 Months) Key - New Employee Start Date: 6-1-14 • Initial Measurement Period = 12 Months A P = Administrative Period = 30 Days Stability Period = 12 Months Key – Ongoing Employee Plan Year - Jan. 1 - Dec. 31 Standard Measurement Period = 12 Months Administrative Period = 90 Days Stability Period = 12 Months *For a new employee who is determined to have worked full-time during the IMP, coverage must take effect no later than the first day of the first calendar month after the employee's first anniversary with the employer (or roughly 13 months after the employee's date of hire).  In order to satisfy this combined limit on the IMP and administrative / waiting period, employers will have to:  1) use an IMP that is shorter than 12 months;  2) use a shorter waiting / administrative period; or 3) adopt a combination of both.

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