People First uses the 12-month look-back method to determine an OPS/Student employee's eligibility for benefits. The
12-month look-back measurement method consists of three different periods:
1. Measurement Period
– counts hours worked for eligibility.
Initial Measurement Period – An OPS
employee who is not reasonably
expected to work at least 30 hours per week at the point of hire. This
measurement includes service from the first day of the month following the date
of hire to the last day of the 12th month of employment.
An example
: An employee is hired October 5,
2018. The initial measurement period will run from November 1, 2018 through
October 31, 2019. If the hours worked during the initial measurement period
average 30 hours or more per week, the employee is eligible to enroll in the
Plan with an effective date of December 1, 2019.
If
a part-time OPS employee at the time of initial hire becomes reasonably
expected to work 30 hours or more per week during the open enrollment
measurement period, the employee becomes eligible to participate in the Plan at
that time.
Open Enrollment Measurement Period – If an
OPS employee has been employed long enough to work through a full measurement
period, the worker is considered an ongoing employee. The hours of service are measured
during the open enrollment measurement period and determined if eligible during
open enrollment. This period runs from October
3 through the following October 2 of each year and will determine Plan
eligibility for the plan year that follows the measurement period.
An example
: Assume one is hired January 5, 2018,
in an OPS position and is expected to work an average of at least 30 hours per
week. The employee is eligible to enroll in the Plan at the point of hire and
will continue Plan eligibility through December 31, 2019. The worker will then
be measured on October 3, 2019, by looking back at the previous 12-month period
to determine if the individual worked at least 30 hours per week. The eligibility
for the 2020 plan year will depend on whether the employee worked an average of
30 hours or more per week during the 12-month measurement period or whether the
employer reasonably expects the individual to work 30 or more hours per week.
Plan
eligibility will continue until ones hours are measured during the next or
second (depending on date of hire) open enrollment measurement period to determine
Plan eligibility for the next plan year.
2. Stability Period – follows a
measurement period. If an OPS employee, the hours of service during the
measurement period determines whether one is a full-time employee who is
eligible for coverage during the stability period. If the individual is a
full-time employee in the stability period, the eligibility is “locked in” for
the stability period, regardless of how many hours worked during the stability
period, as long as the individual remains an employee of the State of Florida.
However, if the employee were a non-full-time OPS employee but become
reasonably expected to work 30 hours or more per week during the stability
period, the individual becomes eligible to participate in the Plan at that
time. For ongoing employees, the stability period lasts 12 consecutive months.
3. Administrative Period – the time
between the measurement period and the stability period when administrative
tasks, such as determining eligibility for coverage and facilitating Plan
enrollment, are performed. If an employee is determined to be eligible, a
benefits package showing the individual’s available options, costs, and effective
dates will be mailed to the mailing address in People First, the system of
record.
The
rules for the look-back measurement method are complex, and this is a general
overview of how the rules work. More complex rules may apply to each situation.
The State of Florida intends to follow applicable IRS final regulations
(including any future guidance issued by the IRS) when administering the
look-back measurement method. If an employee has questions about this
measurement method and how it applies, please call the People First Service
Center at (866) 663-4735 weekdays from 8 a.m. to 6 p.m. Eastern time.
