Temporary and Contract Workers:
The Affordable Care Act’s employer shared responsibility rules will require large employers (50 or more full-time and full-time equivalent employees) to make an offer of minimum essential coverage to at least 95% of their full-time employees or pay a non-deductible excise tax on all their full-time employees. Because the excise tax payments are determined month-by-month, it is not possible to know for certain whether coverage must be offered to any particular employee because of his or her full-time status until the end of a month. Recognizing that this presents something of a Catch-22, the regulators have proposed an alternative means of determining full-time status of certain employees called the “look-back measurement period method.”
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