Question Our company uses the look-back measurement method to identify full-time employees. I recently hired an employee who was expected to work full-time hours. We offered her medical insurance coverage and she accepted. Since then, however, she dropped to part-time hours. What should I do about her benefits? Summary If an employee who is initially…

Question When is COBRA continuation coverage required, and what are some common missteps to avoid? Summary The Consolidated Omnibus Budget Reconciliation Act of 1985 (COBRA) grants individuals the right to continue employer-sponsored health insurance coverage for a limited period after experiencing qualifying events such as a job loss or reduction in work hours. Despite its…

Question We are considering starting an on-site medical clinic where our employees can receive medical care. Can you explain the main employee benefits compliance concerns for such a clinic? Summary Employers providing access to an on-site medical clinic for their employees have several potential compliance issues to consider, including ERISA, COBRA, HIPAA, the ACA, and…

Question One of our employees has been on medical leave for the past four months. Do I have to continue offering our medical insurance benefits or can I go ahead and terminate the medical coverage? Summary Ideally, the question of how long to continue benefits during an employee’s leave of absence (LOA)1 has been proactively…

Question Typically, when we terminate a management or executive employee, we agree to pay all or part of their COBRA premiums for a period of time. What compliance concerns should we consider? Summary While an employer may subsidize COBRA for terminated employees, including management and executives, there are potential compliance traps for the unwary. These…

Question My company is an Applicable Large Employer using the look-back measurement method to determine full-time status of our employees. One of our full-time employees left the company to pursue another career. Four months later, he returned to the company as a part-time employee. Do I need to offer him health insurance coverage? Summary In…

Question We are an applicable large employer (ALE) and we currently operate medical plans and other benefits on a plan year ending March 31st (current plan year ending March 31, 2026). We want to amend our plan year to a calendar year plan so that our employees can better understand the timing and election of…

Question I have hired a couple of interns. They’re scheduled to work full-time hours but they’re only going to be with us for about four months. Am I at risk of any Affordable Care Act (ACA) “Pay or Play” penalties if I decide not to offer these interns health coverage? Summary If the employer is…