Yes. This person is reasonably expected to work on average 30 hours per week as the date of hire.

The final ACA regulations state that an employer “may not take into account the likelihood that the employee may terminate employment with the applicable large employer (including any member of the applicable large employer) before the end of the initial measurement period.”

This employee, then, must be offered coverage by the first day of the month immediately following the conclusion of his or her initial three full calendar months of employment. If they choose coverage, they will be subject to COBRA guidelines upon termination.