Agencies Issue Full-Time Employee Guidance

Just in time for Labor Day, the agencies this afternoon issued two pieces of guidance related to the definition of a full-time employee and the employer penalty provisions of the Affordable Care Act.

The first piece of guidance, Notice 2012-58, sets forth safe harbor requirements for determining who is a full-time employee under the employer penalty provisions. (Remember, the employer penalty only applies to full-time employees.) The safe harbor will be effective for calendar year 2014 only. The notice can be accessed here: Notice 2012-58.

The second piece of guidance, DOL Technical Release 2012-02, provides guidance on the 90-day waiting period limitation and on how the full-time employee definition interacts with the 90-day waiting period. The release can be accessed here: DOL Release 2012-02.

We will be following up with a more detailed analysis in the coming weeks.

Latest Thinking

View more Insights
Insights Center
Knowledge assets are defined in the study as confidential information critical to the development, performance and marketing of a company’s core business, other than personal information that would trigger notice requirements under law. For example,
The new study shows dramatic increases in threats and awareness of threats to these “crown jewels,” as well as dramatic improvements in addressing those threats by the highest performing organizations. Awareness of the risk to knowledge assets increased as more respondents acknowledged that their