Seasonal dating meaning
Misclassifying employees as seasonal employees may result in penalties for an ALE.
The determination of which employees are seasonal employees has taken on new importance for “applicable large employers” (ALEs) because the Affordable Care Act (ACA) measurement method rules allow employers to treat full-time seasonal employees differently from full-time non-seasonal employees, for purposes of group health plan eligibility.
Seasonal effects are different from cyclical effects, as seasonal cycles are contained within one calendar year, while cyclical effects, such as boosted sales due to low unemployment rates, can span time periods shorter or longer than one calendar year.
Seasonality refers to periodic fluctuations in certain business areas that occur regularly based on a particular season.
Employers who hire student interns full-time in the summer and part-time during the rest of the year might want to classify the two positions separately: a full-time summer-only internship position, and a part-time internship position that can be performed anytime during the year.
Summer student interns who transition to part-time positions in the fall would have to be reclassified in the employer’s payroll system.
The likely result is the employee would not qualify as a full-time employee so would not need to be offered health coverage.
This is because an eligibility determination would not occur for 12 months, long after the seasonal employee is no longer employed.
Any predictable change or pattern in a time series that recurs or repeats over a one-year period can be said to be seasonal.
This employee would not meet the definition of “seasonal employee” under the regulations.
As noted initially, misclassifying employees as seasonal employees may result in penalties for an ALE.
On the other hand, for a non-seasonal employee who is reasonably expected at date of hire to work full-time, the employer must track hours monthly and offer health coverage by the first day of the fourth calendar month after date of hire.
(To avoid penalties under the separate –but-similar ACA “90-day waiting period” rules, most employers will likely offer coverage by the first day of the third calendar month after date of hire.) This would apply, for example, for the employee who is hired to work full-time but only for eight months of the year.