Hi. We have an employee that is working two positions within the organization, but for two different sister corporations under the same corporate parent. The parent is the paymaster. On a weekly basis, the employee is working 18 hours in one position and 20 hours in the other. So she is part-time for both. However, her hours collectively are full-time.

Can anyone direct me to regulations or guidance on how to handle health & welfare plan eligibility for this situation? Status is part-time, but total hours is full-time. Does she receive full-time benefits or part-time benefits?

Who is the employer ? Which EIN goes on her W2 etc ? Which company reports her on the state Quarterly employment return ?

The fact that she splits her time might be irrelevant, she might just be an employee of the parent company.

Does the parent also pay the other employees of the siister corporations ?

I received additional information on this employee. The corporate parent's EIN is on the W-2. The difficulty is that one job is her main job, meaning that she has a set schedule. This is the job that controls her job status classification. For the other job, she is classified as "PRN." This means "as needed." In other words, there is no set schedule. Her hours in the second job are all over the map. One month, she could have 40 hours working the second job. Another month, she could have zero.