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ACA Compliance Resources

ACA Compliance Resources

Extra Hours Worked


Question 1: How does Integrity Data handle coding if a company has employees who pick up hours?

Answer 1: For this scenario, the lookback measurement method is the best choice for employers with hourly paid workforces. If an employee is working more than 130 hours in some months, an employer would always be on the lookback measurement method to determine eligibility. Under this method, an employer can test an employee for up to 12 months to determine if they are averaging 30 hours a week (130 hour per month equivalent). For the employee to pass this test they would have to work 30 or more hours in all 52 weeks. So, the occasional extra hours are spread out over time.

Question 2: If an employee works across multiple companies, the hours are calculated within the individual company and then paid in Dynamics GP from each company, how can all the total hours be combined across all companies and make sure they are ACA compliant?

Answer 2: If the companies are in a common control or affiliated group then for eligibility determination, the hours the employee worked in all entities is used to qualify them for access to employer sponsored health coverage. The ACA is designed to eliminate the ability of a company to shift employees’ workloads into multiple entities in order to avoid offering health benefits. Our solution uses a combined group ID for reporting. To set this up, go into the ACA Group Database Setup and designate a unique group ID that will contain all the entities. This will allow the system to reflect all the hours worked.

Question 3:  If an employee receives “on-call” pay, are these hours included in total hours worked?

Answer 3: On call employees have unique rules based on what restrictions they have while being on call. Here are two examples to help explain:

Example A: An employee is required to be on call during the weekend. They are free to use their time as they please with no restrictions and if a support call comes in they will handle the issue off site using company provided equipment. In this case the employer would have to only credit the hours that the employee was actually on support calls.

Example B: An employee is on call during the weekend with restrictions that they are required to report and begin handling the problem within an hour of notification. In this scenario the employee’s use of their free time is clearly restricted. They cannot travel outside an area that would prohibit them from responding within an hour. The employer is then responsible for reporting the employee’s hours as a normal work day. The exact wording in the final regulation states:

“Until further guidance is issued, employers of employees who have on-call hours are required to use a reasonable method for crediting hours of service that is consistent with section 4980H. It is not reasonable for an employer to fail to credit an employee with an hour of service for any on-call hour for which payment is made or due by the employer, for which the employee is required to remain on-call on the employer’s premises, or for which the employee’s activities while remaining on-call are subject to substantial restrictions that prevent the employee from using the time effectively for the employee’s own purposes.”

Click Here for further On-Call information.

Click Here for further information on converting non-hourly compensation to ACA Hours of Service.


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Last Review: 5/24/2022 – Revision: 2.0

Applies To:
ACA Compliance Solution

Categories:  Hours of Service

Keywords:  Lookback, Multiple, On-Call

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