Not really. The reason you should use it for ALL employees is that if a full time employee decided to go part time, the employer is obligated to treat them and test them as if they were a variable hour employee for the entire latest test period completed (SMP or IMP) in order to see if they would continue to be eligible in a corresponding stability period.
If you do not use the FMLA (Unpaid Leave) for a full time employee and this scenario comes – going from full time to part time – you would not be crediting the employee with the right amount of hours.
See this KB link for further information: http://www.integrity-data.com/?s=14-046&lang=en
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Last Review: 9/7/2016 – Revision: 1.0
ACA Compliance Solution
Categories: Hours of Service
Keywords: FMLA, Unpaid