Period may not be longer than 90 days. longest measurement and stability periods possible and thinks it will take 60 days to process data and complete the open enrollment process for newly eligible employees. Compliance might choose a 12-month look-back measurement period from August 1 to July 30, a 60-day Administrative Period from the following August 1 to September 30, and a Stability Period from October 1 to September 30. Under this example, the Administrative Period would take place during the regularly scheduled open enrollment period and the Stability Period would coincide with the plan year, providing the greatest amount of administrative simplicity possible. The Initial Measurement Period, on the other hand, is used for new Variable Hour Employees. Each new employee will have his or her own Initial Measurement and Stability Period. Therefore, at any given time, a large employer will have a Standard Measurement, Administrative and Stability Period and separate and distinct Initial Measurement, Administrative and Stability Periods likely ending in each calendar month. Compliance's conclusion that this is an administrative nightmare is reasonable. The Initial Measurement Period can be three to 12 months in length, with a subsequent stability period that must be the same length as the Stability Period for Ongoing Employees. end of the Initial Measurement Period which may not exceed 90 days. However, the combined length of the Initial Measurement Period and the associated Administrative Period may not extend beyond the last day of the first calendar month after the first anniversary of the employee's start date (approximately 13 months). longest measurement period possible and thinks it will take two months to process data and complete the open enrollment process for newly eligible employees, it may decide to implement an 11-month Initial Measurement Period with a 60- day Administrative period. The Initial Measurement Period must begin on the employee's start date or on any date up to and including the first day of the first calendar month following the employee's start date. on February 15, 2016, Compliance may choose to begin the Initial Measurement Period on March 1, 2016, for administrative simplicity. The Initial Measurement Period would then run from March 1, 2016, through January 31, 2017, and would be followed by an Administrative Period from February 1, 2017, through April 30, 2017. The subsequent Stability Period would run from May 1, 2017, through April 30, 2018. Once a new Variable Hour Employee has been employed for an entire Standard Measurement Period, he or she becomes an ongoing employee the Standard Measurement Period. Continuing our example, Compliance would measure the new employee on the Standard Measurement Period beginning August 1, 2016, so long as he or she remains an employee for that entire Standard Measurement Period. Determining who an employer's full-time employees are is no simple task and will likely require substantial administrative preparation. A company like Compliance or a company for whom the Employer Mandate is not effective until January 1, 2016, should begin preparation immediately. identifies its full-time employees, the resulting penalties may be substantial. an employer of this size should generally have been paying PCORI fees, Transitional Reinsurance fees, and should have applied for a Health Plan Identification Number. However, for purposes of this article, we will focus on the required offer of coverage to full-time employees. applicable large employer maintains a non-calendar year plan as of December 27, 2012, and the plan year was not modified after December 27, 2012 to begin at a later calendar date, no section 4980H penalty will be due for the period prior to the first day of the 2015 plan year). 4 The Measurement Period governs the entirety of the increase or decrease during the Stability Period. 6 26 C.F.R. § 54.4980H-3(d)(1)(vi). This regulation uses 8 26 C.F.R. § 54.4980H-3(d)(3)(vi)(B). 9 26 C.F.R. § 54.4980H-3(d)(1). 10 The Employer Mandate becomes effective January 1, |