ACA Compliance for Rehired Employees

Under the ACA, employees who were terminated and rehired after a gap of 13 weeks or more after termination date, should be treated as a new hire for their lookback measurement. Those who were rehired within 13 weeks should be treated as ongoing employees. 

For employees rehired: 

• Within 13 weeks of termination, the employee should be classified as an ongoing employee per IRS regulations. There will be a single record for such employees in the "Employee Details" tab on the ACA Compliance Overview page. The "Months Requiring Coverage" column will show the employment months under consideration. Clicking on the employee name will show all the relevant months with the appropriate status for each month, in the slideout panel on the right side. The Basic and Employment Information of the employee will show the most recent information. 
  

• Zenefits will generate a single 1095-C form if rehired within 13 weeks. 
  
• After a gap of 13 weeks or more, there will be two records for the same employee in the "Employee Details" tab on the ACA Compliance Overview page. The "Months Requiring Coverage" column will show the appropriate status for each employment period. Clicking on any of the records for the employee will show the same information in the slideout panel - all the relevant months with the appropriate status for each month will be shown. The Basic and Employment Information of the employee will show the most recent information. 

• Zenefits will generate two 1095-C forms if rehired after 13 weeks.