Q: I understand that initial measurement and standard measurement stability periods should be the same length in order to avoid gaps in coverage. However, with a 12 month stability period for both, I am struggling with the rule that the initial measurement and initial administrative period not exceeding 13 months. This leaves me with limited time to identify employees completing their initial measurement period and getting them signed up. Is there anything I can do?
A: Yes, Notice 2012-58 provided some relief when it allowed an initial stability period to exceed the initial measurement period by one month. Under this scenario, an employer can use an 11-month initial measurement period, a 2 month initial administrative period and still have a 12 month initial stability period that coincides with the same length of time of the standard measurement period’s stability period. This approach does not violate the 13 month rule for initial measurement and administrative periods.
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Last Review: 5/2/2016 – Revision: 1.0
Applies To: ACA Compliance Solution and Law for Cloud Users