Calculating Affordability

[Sherwood8189]

As an employer, our employees are classified as Full-Time (35+ hrs per week,) Part-time (30-34hrs per week,) and per diem (less than 30/when we need them.) We charge our insurance premiums based on those classifications. The less hours you work, the more the employee share is. Due to ACA classifying everyone over 30 as full time, when calculating affordability would we need to calculate both the lowest share single coverage price for 30-34 and the lowest share single coverage price for 35+? Or is it just based on our lowest price no matter what hour category we put them in? It is the same MEC and MV plan.

[Flyboyjohn]

Affordability is not a global, all or none, determination, but is determined on an employee by employee basis.

So you'll have to compare the compensation of each employee to the lowest cost option available to that employee.

[Chaz]

As an aside, this plan design might violate the cafeteria plan nondiscrimination tests. Hopefully, this is something that you have considered.