The post below is a guest blog from Rob Kreig who serves as Principal, Health & Welfare Consultant for CAI’s employee benefits partner Hill, Chesson & Woody.
School is almost out for summer, and that means many employers are getting ready to start hiring summer interns. However this year, in addition to determining which students will be the best fit for your organization, you also need to consider how the Affordable Care Act may require you to offer benefits to the interns who you hire.
I’ve been asked numerous times in the last month whether interns who work 30+ hours a week must be offered health benefits on the same schedule as a full-time employee. The answer to this question is generally “yes”. An intern who works more 30 hours a week should be offered benefits under ACA if they are going to be employed for longer than an employer’s eligibility period (can be up to 90 days) if the employer wishes to avoid potential ACA penalties.
However, employers should be aware that there is a possible exception for seasonal workers where some employers are finding that interns may fit. To qualify, the individuals who fill a particular position will work less than 6 months, and are hired at the same time every year. For these individuals an employer can apply the look back measurement method to determine benefit eligibility rather than make the employees eligible at the expiration of a health plan waiting period.
For more information on seasonal employees, the 4th paragraph of question #54 in this IRS document has some additional information including the definition under ACA.
If you have questions about your specific intern situation, check out our free, on-demand presentation: “Temporary Employees and the ACA.”