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Final Regulations Issued Regarding Employer Shared Responsibility Under the ACA
McDermott Will & Emery
[Guidance Overview] Feb. 18, 2014
"Variable hour or seasonal employees who experience a change in status, such that the employee would have reasonably been expected to be employed on a non-seasonal basis on average at least 30 hours of service per week if initially hired into that position, must be provided health coverage by the first day of the fourth calendar month following the change in employment status ... if the employee averaged 30 hours of service or more per week during the initial measurement period."
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