If your organization has an internship program, that’s awesome! Not only are your interns gaining valuable experience and hands-on learning opportunities, but you have built yourself an amazing talent pool to choose full-time hires from, and in the meantime, your company benefits from a fresh, new perspective. If you have hired, or are considering hiring interns at your company, you’ll need to know what the law has to say about their health benefits.
When are you Required to Offer Health Insurance to Interns?
First, you’ll need to define the scope of the intern’s work and their status at your organization. Is the intern paid? Do they work full or part-time? The answer to whether you’ll need to provide health insurance to interns will also depend in part on whether your company qualifies as an “ALE,” or Applicable Large Employer under the Affordable Care Act. In brief, an ALE is an employer with an average of at least 50 full-time employees.
Do Small Businesses Have to Offer Health Insurance to Interns?
If you are not an ACA-defined Applicable Large Employer, you don’t need to offer health insurance to any of your interns, whether they’re full or part-time, paid or unpaid. However, if you choose to offer them insurance, you’ll need to review the terms of your health insurance plan’s plan document. Based on the plan document’s eligibility provisions, you can determine whether your interns fall within those standards for coverage.
Do Large Employers Have to Offer Health Insurance to Interns?
If you are an ACA-defined Applicable Large Employer, the ACA requires you to offer minimum essential coverage to all full-time employees. According to the ACA, a full-time employee is one who works 30 hours or more each week. Those thirty hours, however, must be hours that are either paid or entitled to payment.
Unpaid interns have no hours which are either paid or entitled to payment. Therefore, as an ALE, you are not required to offer unpaid interns health insurance. The same goes with paid interns who only work part-time: ALEs are not required to offer these interns health insurance under the ACA.
If you are an ACA-defined Applicable Large Employer and you have paid, full-time interns, you will only need to offer health insurance if they work longer than the ACA’s maximum 90-day waiting period. Past this period, ALEs should plan to offer coverage to all paid, full-time interns.
Keep in mind that there are many exceptions to these rules, and certainly plenty of intricacies. For example, if your full-time, paid interns came to you through a program sponsored by the federal government, they will likely be excluded from health insurance requirements. And if your interns are 26 years old or younger, and their parents have qualifying insurance, they don’t need always to be offered health insurance, either.
Making sense of health and benefits requirements for interns can be tricky for even the most seasoned human resources professionals. When you need to make the right decision, it always helps to talk to Employee Benefits & Compliance Experts. Contact Benely for assistance, or request a free demo today.