• Coverage Requirements. To satisfy the employer mandate for 2015, an employer must offer coverage to at least 70% of its full-time employees. This coverage requirement will increase to 95% of full-time employees for 2016 and later years.
• Determining Status as Applicable Large Employer. For purposes of determining whether an employer has the requisite number of full-time employees or FTEs to be subject to the employer mandate in 2015, an employer may use a period of at least six consecutive months (instead of an entire year).
• Measurement Period for Determining Full-Time Employees. Under the look-back measurement method, an employer may determine the status of an employee as a full-time employee during a subsequent period (referred to as the stability period), based upon the employee’s hours of service in a prior period (referred to as the measurement period). To determine the number of full-time employees for 2015, on a one-time basis, an employer may use a six-month measurement period, even with respect to a stability period of up to twelve months.

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