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Look-Back Measurement Method and COVID-19

Posted 04.02.20

The evolving coronavirus (COVID-19) pandemic has caused some confusion and uncertainty in applying the look-back measurement method during periods of layoff, furlough, and COVID-19 related periods of paid and unpaid leave.

Federal agencies have not issued guidance regarding the ACA’s employer shared responsibility rules in light of the COVID-19 outbreak. As a result, the general rules for determining employee status apply.

This ACA Compliance Bulletin provides information for employers regarding how the look-back measurement method applies to COVID-19 related absences.

Look-back Measurement Method and COVID-19

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