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State RegulationsOH specificDifficulty 3/5

An employer averaged 12 eligible employees on business days during the preceding calendar year, but only 1 eligible employee was on its payroll on the first day of the new plan year. Under ORC 3924.01, the employer:

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Answer & full 3-part explanation (select an option above, or peek)

Why D is correct

ORC 3924.01 contains two cumulative conditions: the preceding calendar year must show an average of at least 2 but no more than 50 eligible employees on business days, and the employer must have at least 2 eligible employees on the first day of the plan year. This employer satisfies the 12-employee average but fails the first-day minimum of 2, so it is not a small employer for that plan year.

Why the other options are wrong

  • A) The preceding-year average is not the only test; ORC 3924.01 adds the first-day condition.
  • B) ORC 3924.01 expressly requires at least 2 eligible employees on the first day of the plan year.
  • C) The employer is not permanently excluded — it qualifies whenever it meets both the average test and the first-day test.

Memory hook

Two gates: 2 to 50 average last year AND 2 on day one — miss one, fail both.

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