Counting Hours for Summer Camp Employees

[Guest Cookie10]

I'm working with a new 403(B) plan. Employees who work 1,000 or more hours per calendar year are eligible to join.

In addition to our regular staff, we have several hundred seasonal employees who work at our summer camps. They are paid in full and half day increments plus room and board. For the "normal" employees like archery instructors, cooks, etc, it's easy to convert the daily rate to hours. They don't come close to 1,000 hours. However, I'm not sure how to count the hours for the Unit Counselors. They sleep in the same cabins with the kids and are technically on call in case of emergency even when asleep (nightmares, wet beds, etc). Do I have to count that as 24 hours for each day worked? If so, they would hit 1,000 hours with about 7 weeks of work.

[QDROphile]

Assuming that you have have taken into account the universal availablitity rules applicable to elective deferrals in section 403(b)(12) and are talking about ERISA coverage requirements, extensive regulations address how hours are counted.

[Kevin C]

The universal availability issue comes from the regulation 1.403(b)-5(b)(4)(i) all or nothing rule for excluding those who work under 20 hours per week. There have been several threads about this issue in the last couple of years. If your plan is ERISA covered, that only increases the risks of using the <20 hours per week exclusion.

You will also need to look at how the plan document defines an hour of service.