Interns are just employees by another name

Related:Hot summer hiring expected for second yearstraight

What about seasonal employees?

Are your interns really seasonal?

Proceed with caution

Practical tips

  • Offer coverage to full-time interns. If youaren't sure your full-time interns are truly seasonal, or you wantto be sure you avoid any risk of facing a costly penalty, thenoffer your interns health insurance coverage. As a practicalmatter, most of them are likely on their parents' plans and won'ttake it, so this is a “better safe than sorry” approach. In manycases, internships may not last long enough to complete the waitingperiod. Additionally, if you decide to hire them full-time out oftheir internship, you've already made an offer, so you don't haveto make a second offer again until the next open enrollment.
  • Analyze and document your findings. If youwant to categorize your interns as seasonal employees, be sure todo a careful analysis and document how you arrived at thisdetermination.
  • Not all internships are created equal. Even ifyou are comfortable that some of your intern positions are trulyseasonal, others may not be. For that reason, aposition-by-position analysis is advised.
  • Watch out for “season creep." If your interns(or any “seasonal” employees, for that matter) regularly work morethan six months, then they really aren't seasonal for ACA purposes.Be on the lookout for requests for extensions of time or jobs thatregularly extend their service beyond the six month limitedwindow.
  • Make interns wait. Some employers who do nothave a 90-day waiting period may impose a 90-day waiting period oninterns only. This may be permissible, but care should be taken anytime a particular employee group is singled out as it may raisediscrimination and other concerns.
  • Make the necessary adjustments. However youultimately decide to address interns, be sure to adjust payroll,HRIS, and enrollment systems to accommodate your intended treatmentof interns.

Carrie Cherveny is the senior vice presidentof strategic client solutions in Hub International's Risk Servicesdivision.Cory Jorbin is the CentralRegion compliance officer for global insurance brokerage HubInternational's employee benefits practice.

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