Under the Affordable Care Act (ACA), the number of full-time employees determines whether an employer must offer affordable group health benefits. The ACA allows you to use the look-back/stability measurement method to determine whether employees are full-time employees. You set the length of your periods, provided they’re equal and aren’t longer than 12 months.
Although it’s clear that you can’t restart the measurement clock when employees transfer, it’s less clear how you apply the periods once a transfer occurs. The IRS has proposed rules that clarify how differing periods apply to transfers. You may rely on these rules until further guidance is issued, and, in any case, through 2016. (Notice 2014-49, IRB 2014-40)
Employee-initiated transfers. A transfer that may result in changed look-back measurement periods (i.e., periods that have different durations, start dates or both) occurs, for example, when employees transfer a...(register to read more)