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Understand the Affordable Care Act's Shared Responsibility Mandate, including coverage requirements, affordability guidelines, and penalties for non-compliance. Learn about tracking time worked, reporting requirements, and the impact on employee categories. Get ready for the 2015 transition tracking period and proposed definitions for student employees.
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Shared Responsibility Mandate • If employer offers coverage, must be offered to 95% of full-time employees • Must be Affordable • Must meet Minimum Value Standards • Use Safe Harbor guidelines to determine track time of
Coverage • Defined as: • 95% of full-time employees • Full-time is defined as average of 30+ hours per week • Includes employee’s children to age 26 • Spouses or domestic partners not required • Must have the opportunity to enroll at least once per year
Affordability • Affordable coverage is coverage that is 9.5% or less of household income • Federal government offered 3- Safe Harbors to employers • USG is using the Federal Poverty Line Safe Harbor: Must offer coverage with an employee premium that is 9.5% or below the Federal Poverty level • 2014 Federal Poverty level is $11,680; • 9.5% of $11,680 is $1,110 or a monthly premium of $92 • USG High Deductible Health Plan monthly premium is $47 • Under Safe Harbor, employee is not eligible for subsidy in the exchange market and USG would not be subject to penalties
Minimum Value • 60% minimum plan value based on ACA rules definition of “essential health benefits” • Healthcare Plan’s actuary has confirmed all USG Healthcare plans meet Minimum Value coverage as defined by ACA
Penalties for not meeting Shared Responsibility requirements • If don’t meet coverage requirements: • $2,000 times total number of FTEs – not counting first 30 FTEs if don’t meet coverage requirements • If don’t meet affordability requirements: • Up to $3,000 annually for each FTE receiving income based assistance for health insurance exchange coverage • Each USG institution’s management is accountable and responsible for achieving and maintaining compliance with the requirements under the Affordable Care Act • Each USG institution will be held financial accountable for non-compliance
Tracking Time Worked- initiallyall employees not offered health insurance • Safe Harbor Tracking Method • Look-back or measurement period (3-12 months), this is the period of time in which hours will be tracked for part-time employees; standard year after year • After the measurement period, employers have the option to have an administrative period (up to 90 days); this period is used to determine eligibility and facilitate enrollment of any employees who meet eligibility • Stability period – period during which part-time employees who met eligibility may elect to participate in the healthcare plan (6-12 months) • Hours worked for faculty must be calculated based on the academic year to determine eligibility unless they work during the summer
Reporting • Employers are required to report their employer provided health coverage data to the Federal Government
Three Major Impacts • Must revise the USG Employee Category Policy and the definitions of employment and employee types • Develop a Conversion Chart for Credit hours to hours worked for part-time faculty • Set up tracking method to determine health benefits eligibility for part-time workers
Final Guidance Released February 10, 2014 • Further Guidance on types of employees and hours of service • 2015 Transition Tracking Period Provisions • Transitional 6 month tracking period • Must begin
Definitions from Guidance • Seasonal • Variable Hour • Adjunct Faculty • Rehired employees
Proposed Definition of Student Employees • Currently not exempt under ACA • Proposed solution is to revise the Employee Category Policy: • Students must work part-time except during the summer and holidays and may not exceed 1300 hours in any consecutive 12-month period • International students and work study students must work no more than 20 hours per week
Next Steps • Collect feedback from this group and from system-wide VPAAs, CBOs, and CHROs, last week of February or first week of March • Finalize documents and distribute system wide mid-March • Training sessions first two weeks in April
