Should we offer summer interns group health insurance?

Do we need to offer summer interns group health insurance?

Offering benefits to interns can enhance your employment brand and reputation in college placement offices and within the labor marketplace overall. However, you may not be required to offer coverage, and whether you do or not will depend on your health plan design.

Summer interns by nature are “temporary” employees as their duration of employment is expected to last not more than the summer (e.g., 90-120 days). While you can classify these employees as temporary, their eligibility for benefits will be determined by the terms of your group health insurance plan and the terms of any other company-provided benefits policies.

With respect to healthcare benefits, temporary or seasonal workers don’t qualify under many plans. Employees who work less than six months are often excluded from the plan and not offered coverage per the plan's guidelines. However, if the temporary work period exceeds six months, they would usually be treated as a regular employee, even if they are being classified as ”temporary” in the employer’s internal systems. We recommend you check with your insurance broker to see if there is specific wording that would make temporary or seasonal workers eligible under your plan.

If your summer interns are eligible, you should provide them with access to this benefit per your usual time frames and policies. We recommend you confirm your plan’s exact rules with your carrier or benefits broker to ensure you’re following your plan’s expectations.

Note: Applicable large employers (ALEs) may be required to offer group health insurance benefits to avoid potential penalties under the Affordable Care Act (ACA). ALEs are employers that had an average of 50 or more full-time equivalent employees in the prior calendar year. Under the ACA rules, interns can be defined as seasonal employees when hired into positions for which the customary annual employment is six months or less. The ACA requirement to offer health insurance may be triggered for seasonal employees (interns) depending upon a complex set of rules. Employers with fewer than 50 full-time equivalent employees are exempt from this ACA requirement.

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