On Sept. 18, 2014, the Internal Revenue Service (IRS) issued Notice 2014-49, which describes a proposed approach for applying the look-back measurement method if the measurement period for a particular employee changes. This notice addresses measurement period changes resulting from the following situations:
- An employee transfers from one position to another within the same Applicable Large Employer ALE (or ALE member), where a different measurement period is used for each position; or
- The ALE changes the measurement period applicable to a category of employees.
ALEs may use different measurement methods (either the look-back measurement method or the monthly measurement method), or may use measurement periods that differ in length or start on a different date, for the following specified categories of employees:
- Collectively bargained and non-collectively bargained employees;
- Each group of collectively bargained employees covered by a separate collective bargaining agreement;
- Salaried and hourly employees; and
- Employees whose primary places of employment are in different states.