Final Rule for NON Calendar plan measurement period

[Guest velazro1]

The Final rules came out on February 14, 2014. Does anyone know how the measurement period would work for a plan that has a September 30th plan date? I noticed in the regulations that the measurement period can not start later then July 1, 2014. However, the measurement period can not be longer then 12 months and the administrative period has to be less than 90 days. Please help.

[Flyboyjohn]

Happy to help.

Start with renewal date (10/1/2015) and work backwards to determine if you're going to want/need an "administrative period" of up to 90 days. Since there are more than 90 days in the 3 calendar months of July-September 2015 you won't be able to end your measurement period on June 30, 2014 as you might like.

So for "calendar month" simplicity let's say you decide to use a 2 calendar month administrative period of August and September, 2015. This now tells you your measurement period will need to end on July 31, 2015 and will have to be 12 months long (begins 8/1/2013) since the special 6 month short measurement period rule only applies if your initial measurement period starts by 7/1/2014.

Bottom line: the "shorter than 12 month" special measurement period under the final regs doesn't do you any good for renewals dates after about August 1st or so (you'll be using regular 12 month measurement periods for those).

[Guest velazro1]

Dave, did you mean begin the measurement period on 8/1/2014, not 8/1/2013? Also, if we use the measurement period that you described, are we still able to utilize the transition relief for a NON Calendar year plan. We meet the 1/3 of coverage for full time (30+hours) on 1/14/2014.

Dave, so, the Final Rule that states that the measurement period has to

start before July 1, 2014, only applies if you are using a 6 month

measurement period. We qualify for the transition relief because we covered

1/3 of all employees that worked 30 hours or more on January 12, 2014. Our

plan is to use a 12 month measurement period.

[Flyboyjohn]

Messed up 2 dates in my original response:

First paragraph should end "...and end your measurement period on June 30, 2015 as you might like."

In second paragrpah should say "begins 8/1/2014"

Lastly, you're correct that the 7/1/2014 measurement period start date only applies if you trying to use a less-than-12 month measurement period.