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Student Employees and the ACA, Part 4 of 4: If Students Are Employees, How Are Their Hours Counted?
Mintz Levin Link to more items from this source
[Guidance Overview]
June 14, 2015

"The IRS provides no clear methodology for counting and tracking resident assistant hours.... [W]here hours of service are particularly difficult to identify or track, an employer should use a 'reasonable method of crediting hours of service that is consistent with [Code] section 4980H.' The IRS has also offered the following guidance, which is illustrative (albeit not quite on point): The 'adjunct faculty' safe harbor.... 'On call' employees."

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