For new hires, when does the initial measurement period start, on date of hire, or 1st day the following month?
Measurement periods are used by employers to determine full-time status for new-hires and existing employees in regard offering health coverage under the ACA's employer mandate.
These periods are complex, but can be summed up as: periods of 3 -12 months used to determine full-time status AND periods used to determine the length of time coverage has to be offered for (after an employee is full-time they must be offered coverage until the end of the calendar year, which is 12 months maximum and 6 months minimum; 3 was pushed for but rejected).
For both new-hires and existing employees, the initial measurement period starts on the 1st of the calendar month after the employee start date or at the start of the payroll period. Employers should make sure to take into account initial and standard stability periods and standard measurement periods as well. They all typically start on the 1st day of the month or on the start of payroll.
Initial measurement for new hires is 3-12 months, standard for ongoing employees is a 12 month calendar year.
If the employee works more than 30 hours a week or 130 in a month, for more than 120 days in a year, they are full-time in regard to ObamaCare's Employer mandate. As another part of the mandate employers need to count all employee hours during initial and standard measuring period to determine if they are required to provide coverage or get a fine. Employers must look at both initial measuring and standard measuring periods, as one can override the other.
It makes sense to tie the Initial Measurement Period to the start of a payroll period which is allowed under the proposed regulations. Remember employees can't have longer than a 90 day wait time for health insurance to start.
Here is some more information on using payroll period start dates for look-back periods and initial measuring periods.
There are two sources that explain this very well (outside digging through the laws and federal registers). They are:
media-services.com - simplified explanation of employee measurement periods under ObamaCare
moulderlaw.com - complex but more detailed explanation of employee measurement periods under ObamaCare.
TIP: Employers must remember that once an employee is full-time, they must generally be offered coverage for the duration of the stability period as long as they remained employed (even if they switch to say 5 hours a week a day after officially becoming full-time).