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Employers need to keep track of monthly hours throughout 2014 to determine if health coverage must be offered in 2015 and which employees are eligible.

Employers should be recording all employee hours of service including both hours actually worked and hours paid to employees for time that is not worked, such as vacation and sick time, jury duty, leaves of absence, military duty and disability (these are for salaried employees only).

To calculate total hours of service for salaried employees, employers can utilize one of three techniques.

  • Count actual hours of service from records of all paid time
  • Assume at least eight hours of pay for each day of service (days-worked equivalency)
  • Assume at least 40 hours of pay for each week of service (weeks-worked equivalency)

Note: Employers can only use the days-worked or weeks-worked equivalency methods if it doesn’t understate hours or cause full-time employees to be categorized as part-time.

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