Determining Full-Time Employee Status for Purposes of the Employer Shared Responsibility Provisions under ACA

The focus of this article is on determining employee status for purposes of the employer mandate. Updated January 2021.

Knowing who is considered to be a full-time employee is important not only for determining an employer’s size for the purpose of determining whether the employer could be penalized for a failure to offer affordable coverage with minimum value, but also for determining which employees could trigger a penalty for an employer under the Patient Protection and Affordable Care Act ("ACA"). The focus of this article is on determining employee status for purposes of the Employer Mandate penalty calculations, not on determining employee status for purposes of determining employer size^.1

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Sources

¹ For information on determining an employer’s status as an applicable large employer, see our article "Final Regulations on How to Calculate Applicable Large Employer Status."