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Final Play-or-Pay Regulations Include Significant Transition Rules
Spencer Fane Link to more items from this source
[Guidance Overview]
Feb. 25, 2014

"A new employee whose hours equal or exceed the 130-hour threshold must be treated as full-time by the end of the third full calendar month after the employee's date of hire. To avoid being subject to a play-or-pay penalty with respect to such an employee, his or her employer must then make an offer of health coverage by the following day (i.e., the first day of the fourth full calendar month after employment). Note, however, that this deadline applies only for purposes of the play-or-pay provision. If an employee is hired into a position that is otherwise eligible to participate in the employer's health plan, the employer must allow that employee to enroll in the plan within 90 days after being hired. Otherwise, the employer will face a different ACA penalty."

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