Affordable Care Act Guidelines for Casper College Published July 2015 Health Insurance Eligibility

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1 Affordable Care Act Guidelines for Casper College Published July 2015 Effective January 1, 2015, the Patient Protection and Affordable Care Act (ACA) requires large employers (50 or more employees) such as Casper College to offer health insurance benefits to any employee averaging 30 work hours or more per week. This requirement is often referred to as the employer mandate of the ACA. Casper College s insurance provider, the Employer's Group Insurance program with the State of Wyoming, requires that we offer all employees who work 20 hours per week or more with health insurance benefits. Thus, insurance eligibility at Casper College is offered to employees averaging 20 hours per week or more. To comply with the ACA and ensure that all Casper College faculty, staff and students who average 20 or more work hours per week are offered health insurance benefits, it is imperative that departments and supervisors monitor the employment of, and hours worked, by part-time, non-benefited employees. At Casper College, non-benefited employees include: Adjunct Faculty Continuing Education Instructors On-call Employees Regular Part-time (non-benefited) Classified Staff Student Work Study Employees Temporary/Seasonal Employees Health Insurance Eligibility The ACA provides the following method to determine if a non-benefited employee has reached the weekly threshold and should be offered health insurance: For existing non-benefited employees (active as of the start of the measurement period) Casper College will look back at a 12-month measurement period to determine whether an employee averaged 20 work hours per week. The measurement period will begin on the first day of the pay period that includes December each year. If an employee works an average of 20 hours or more per week during the measurement period, the employee must be offered employer-sponsored benefits for a period of time in the future known as the stability period. The employee continues to receive employer-sponsored benefits regardless of hours worked during the stability period. The stability period is December 1 - November 31 each year. The first stability period began on December 1, 2015.

2 There is an administrative period between the measurement and stability periods. This is when Human Resources will determine and notify employees who have become eligible for health benefits and when these eligible employees will enroll for a January 1 effective date. The administrative period will begin at the conclusion of the measurement period and continues until November 31 each year. The first administrative period began on November 1, The initial measurement period will be November 1, October 1, 2015 Employees who average 20 or more work hours per week during this time are eligible for benefits effective December 1. For new non-benefited employees (hired after the start of a measurement period), each new employee will have an individual 12-month measurement period that begins on the first day of the month following the date of hire. Adjunct Faculty and the ACA Per guidance from the IRS and from our Academic Affairs office, the standard calculation for normal credit courses is 2.2 per credit hour of instruction, per week. Thus, a standard 3 credit course equals 6.6 hours worked, per week. The most an adjunct instructor may teach per semester is two 4 credit courses, which would equate to Because the ACA measures time over a 12 month period and uses an average, adjunct instructors may teach more classes one semester over the other, granted the total 12 month average stays under 20 hours on average, per week in the measurement period. Music studio instructors, lab course instructors, and other non-typical assignments will be calculated using a flat hour ratio (1:1). Casper College's responsibilities To prevent penalties from being imposed, Casper College must be 70% compliant in 2015 and at least 95% compliant by 2016 and thereafter. To ensure ACA compliance, Casper College must: Provide marketplace notices to existing and new employees Ensure that the benefit coverage for all existing benefit-eligible employees meet the ACA requirements of affordable coverage and benefit value. Establish a standard measurement period of 12-months to measure the employees' average weekly work hours and determine who is eligible for benefits.

3 Offer healthcare insurance benefits to any and all eligible employees who average 20 work hours or more per week during the standard measurement period. Monitor the initiation of initial stability period for newly benefit-eligible employees. Ensure the work rule that non-benefited employees only average 19 work hours or less per week during a standard measurement period. Establish a calculation of hours for part-time facult Provide information about breaks in service. Create and implement tools to help departments and employees manage average weekly hours worked. Provide guidance to departments and employees as needed. Supervisor Responsibilities It is important for departments to monitor any and all variable hour employees to ensure ACA compliance. If employees average 20 work hours or more per week in a measurement period, Casper College has to offer healthcare insurance to the newly eligible employees. To ensure compliance, supervisors must: Monitor all non-benefited employee average work hours per week over a measurement period. Work with departments across colleges/campuses to coordinate work schedules for variable hour employees if they hold two or more positions. Ensure that variable hour employees are compensated for every hour they work (part time faculty are paid based on the number of credit hours taught). Understand the calculation of hours for part-time faculty. Understand the 'break in service' rules for part-time employees. Employee Responsibilities Variable hour employees can monitor their average weekly hours in order to continue to maintain their variable hour status. To ensure compliance, employees must: Communicate with supervisors about all employment at Casper College. Report all hours worked. Read the marketplace notices.

4 Measurement Period Chart Calculating the Average Whenever an employee is receiving pay and hours are being reported, those hours must be included in the average calculation. This includes not only work hours but any paid leave time, such as vacation leave, sick leave, and other varies paid leave (see policy). If an employee is working continuously during the measurement period, calculating the average hours worked per week is straightforward; total all the hours worked in the 12 month measurement period and divide it by the total number of weeks worked (52), treating any paid time off as hours worked. A helpful calculation for supervisors would be to manage this monthly, limiting hours at 80, by adding up the total time worked in any month. Monthly reports will be provided by HR. One particular issue with how the ACA indicates on how we should calculate average hours is how breaks are treated. A break period is any time during the measurement period when an employee does not receive pay. The employee may have zero work hours, be on a short break, or be terminated. This break period may influence the average hours worked calculation.

5 Break Information Unpaid time lasting less than four Unpaid time lasting from 4 to 26 Unpaid time lasting more than 26 Unpaid Family and Medical Leave and unpaid USERRA (military) leave The weeks with zero hours reported are calculated in the average calculation. The weeks with zero hours reported are not included in the average calculation. Therefore, the average will be calculated using fewer than 52 weeks. The employee continues in the same measurement period he/she was in when the break started. On returning to work, the employee may be treated as a new hire with a new 12 month measurement period that begins the month of rehire. These weeks are not included in the average calculation. Therefore, the average will be calculated using fewer than 52 weeks. Based on this information, winter and summer breaks count towards the calculation and the average is taken from weeks worked, and weeks while on break are not factored in the calculation.