Regardless of the particular measurement period employers select to determine which of its part-time, temporary and seasonal workers may be benefits-eligible under health care reform, they will need a robust time and attendance system to perform the calculations, benefits experts say.

Communications also will be important in educating employees about their benefits eligibility, the experts say.

Fortunately, most payroll and human resource information system vendors either already have those capabilities or are building them to meet the new employer record-keeping requirements mandated by the Patient Protection and Affordable Care Act.

Newport Beach, Calif.-based Secova Inc., for example, has developed a platform with the capability to take in-time and attendance information to calculate full-time employees on a real-time basis, and to conduct automatic enrollment into benefits programs, among other things, said Chirayu Patel, vice president of client development.

Secova's iElect system, which originally was designed for large employers with between 5,000 and 15,000 employees, was retooled in 2009 to also service middle-market employers and soon will be available to employers with as few as 100 employees, Mr. Patel said.

“For medium-size and small businesses, meeting the full-time employee test is going to be a challenge,” Mr. Patel said. Determining which employees meet the full-time equivalency test is only the start. “They also will need to determine whether they qualify for the tax credit or the exchanges,” he said.

“For employers, the idea of a robust time and attendance system and superior record-keeping are certainly going to be emphasized to document your exposure or lack of responsibility for providing health benefits,” said Karen Vines, vice president of employee benefits at broker IMA Inc. in Wichita, Kan.

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“The guidance gives employers the framework for tracking which individuals may be benefits-eligible, but a lot of the record-keeping is going to be up to the employer to self-certify what their population looks like,” she said.

“I don't know if the tracking is going to be any more cumbersome than it has been in the past, but now employers have a real incentive to make sure they are tracking correctly. And there's going to be a bit more scrutiny. Employers will have to be ready for audits,” said Don Garlitz, executive director of exchange solutions at bswift, a benefit technology firm based in Chicago. Fortunately, “the tools are out there in the marketplace.”

This PPACA provision “will create some record-keeping and employee communications issues,” said Pat Haraden, a principal at Longfellow Benefits in Boston. “When the regulators allow employers a choice, you will create this education vacuum among employees.”

This happened during implementation of an earlier provision in PPACA requiring benefit plans to provide 100% coverage for preventive care services, he said. This mandate did not apply to benefit plans that were grandfathered, he said.