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Testimony before Department of Treasury on ACA Employer 'Shared Responsibility' Provisions (PDF)
The ERISA Industry Committee [ERIC] Link to more items from this source
[Opinion]
Apr. 23, 2013
"First and foremost, ERIC encourages the agencies to clarify the methodologies available to employers for counting an employee's hours of service. It is absolutely essential ... that employers be permitted to use one methodology to count hours for those who are clearly either full-time or part-time employees on the date of hire, and to use a different methodology (such as the lookback safe harbor) to count hours for so-called variable hour employees."

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