Jose Turner57 said:How’s the employee registration process looking lately? I haven’t had to onboard or offboard anyone in about six months.
I see that filing with NOAA is sufficient.
But for Medicare, do I just need to have a registered application on file?
1. One of my employees had a contract expire on September 30th, 2014. Since the new labor laws just kicked in, I’m not sure if I can re-register them for a fixed-term contract, or if I even need to report that to NOAA.
2. What’s the standard procedure now when we’re enrolling someone on a fixed-term basis for the first time under the updated IRS guidelines?
3. When we extend an existing fixed-term agreement, do we need to notify NOAA, and do we have to provide a reason for the extension?
Sorry to be a nuisance; you guys have probably already covered this in previous threads...
Using the Medicare application isn't strictly mandatory, though it is practical for several reasons—one being that you receive the registration/de-registration forms via email. If you don't use the application, you must physically go to the service counter with a completed form to have it verified, as you need official proof of the registration or de-registration.
It is true that emails can take some time to arrive, but they eventually do. If you are de-registering an employee, they can actually head straight to the service counter without waiting for your paperwork to claim unemployment benefits; they don't necessarily have to wait for your confirmation.
1. You really need to clarify this point. You are likely concerned about the specific IRS provisions regarding the time limits on such contracts. Since you know how long the previous contract lasted, perhaps you should review that specific section of the law.
2. Registering an employee on a fixed-term basis with NOAA is handled exactly as it was before—just the standard M1P form and nothing more. The IRS did not introduce any changes regarding that specific procedure.
3. Extending a fixed-term contract does not require reporting to NOAA. If one contract ends on September 30 and the next begins on October 1, you simply draft the new contract; you don't submit anything to them—neither the contract nor a change form—because technically, no change has occurred. However, if a contract transitions into a permanent position, or if there is a change in working hours (full-time vs. part-time), then a notification of change is required.
Regarding the explanation you asked about: that detail is vital to include within the contract itself. You must provide a solid justification for why the work is fixed-term and for the subsequent extension. NOAA has no involvement in that matter.