A conference call held on Tuesday by an American Bar Association committee highlighted the need for employers to begin thinking about procedures for part time employees under the Affordable Care Act.  Attorney Henry Talavera told listeners on a conference call held by the ABA’s Joint Committee on Employee Benefits that employers should begin identifying part-time employees now prior to the 2014 deadlines, according to the Bureau of National Affairs.

Beginning January 1, 2014, employers that hire seasonal or part-time workers would be fined if they failed to provide insurance to these employees if they qualify as full-time, not part-time, employees (see the IRS guidance here).  Employers can have a look-back period of up to 12 months under Department of Labor guidance, so Talavera recommends that employers begin to plan now on managing employee hours as well as planning on who they need to extend insurance.  This guidance and planning will be critical to retail, restaurant, and agricultural employers, who are major employers of seasonal employees.  However, all associations that hire part-time workers need to check and see how part-time their employees are, and what benefits must be extended to those employees.