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Seasonal Rehire Employees in the Affordable Care Act (ACA)


Question: If a company hires seasonal employees throughout the year, some may be new and some may be rehired multiple times for different positions, how does the ACA module handle multiple rehires?

Answer: Seasonal employees are classified like other employee in regards to rules governing when they are coded as a rehire.   When an employee’s adjusted hire date is changed, it moves the employee out of whatever testing period they were in and restarts them on another individual initial measurement period.   Classifying an employee as a rehire and adjusting their hire date is at the sole discretion of the employer.  The rules for when an employee can be classified as a rehire are as follows:

  1. The employee was absent from service for 13 consecutive weeks (26 weeks for educational institutions)
  2. The employee had previously worked at least 4 weeks and their subsequent absent of service was greater than what they previously worked.

The words “sole discretion of the employer“ can be located in the rehire section of the final regulation for the Employer Mandate which was issued in February 2014. An employer may or may not elect to treat an individual employee as a rehire.

Example: If the employee was absent for 20 weeks, an employer may not want to reclassify them as a rehire and instead adjust their hire date.  In this scenario because the absence was quite lengthy, the employee would probably not qualify for health coverage if they remained in their present measurement period.

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Last Review: 8/12/2022 – Revision: 2.1

Applies To: ACA Reporting Requirements, ACA Compliance solution

Categories:  Rehire

Keywords:  Seasonal, rehire

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