It is expected that current DOL rules for counting hours for pension plan purposes will be used to count an employee’s hours of service as a full-time employee or full-time employee equivalent. Under these rules, a person is considered to have completed an “hour of service” with each hour for which he is paid for work, vacation, holiday, sick time, layoff, jury duty, military duty, etc.
When converting time to a monthly basis, 30 hours per week would mean 130 hours per calendar month.
The agencies are considering several possible methods of counting hours and have said that they expect that employers will be able to use different counting methods for different classes of employees. The proposed methods include:
• For employees who are paid hourly, actual hours worked or paid would need to be used
• For employees who are not paid hourly, alternatives would include:
- Counting actual hours worked or for which vacation, holiday, etc. are paid
- Crediting an employee with eight hours’ work for each day for which the person was paid for at least one hour of work, vacation, holiday, etc.
- Crediting an employee with 40 hours’ work for each week for which the person was paid for at least one hour of work, vacation, holiday, etc.
How Will Part-Time Employees Be Counted?
Employees who work less than full-time (30 hours per week) count towards “full-time equivalent employees” when deciding if the employer has 50 employees. Full-time equivalent employee numbers would be determined by:
• Using the hours of service each month for each person who worked an average of less than 30 hours per week during the month
- This includes the hours of seasonal employees who averaged less than 30 hours for that month
- A maximum of 120 hours of service should be considered for any employee who is not full-time for a month
• Counting fractions for each monthly total, but rounding the total annual number down.
“Seasonal employees” would mean retail employees who work only during holiday seasons and others who perform work that by its nature is only performed at certain times of the year (such as harvesting or tax season).
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