PATIENT PROTECTION AFFORDABLE CARE ACT (PPACA) GUIDE

Transcription

1 PATIENT PROTECTION AFFORDABLE CARE ACT (PPACA) GUIDE HEALTH INSURANCE COVERAGE AND TAX REPORTING REQUIREMENTS FOR PARTICIPATING ENTITIES (INCLUDING PARISHES) OF THE ARCHDIOCESE OF DENVER WELFARE BENEFITS TRUST (THE TRUST ) ISSUED BY THE ARCHDIOCESE OF DENVER MANAGEMENT CORPORATION, PLAN ADMINISTRATOR FOR THE TRUST JULY 2015 PREPARED BY THE OFFICES OF HUMAN RESOURCES (HR), LEGAL SERVICES (LS) AND PARISH FINANCE (OPF)

2 TABLE OF CONTENTS INTRODUCTION... 3 BACKGROUND HEALTH CARE REPORTING AND TRACKING HOURS REQUIREMENT TRACKING AND REPORTING TOOL... 4 TIME TABLE FOR TRACKING HOURS OF SERVICE... 4 WORKER CLASSIFICATION... 6 EMPLOYEE CLASSIFICATION... 6 STANDARD WORK WEEK... 6 TIME SHEETS... 7 FULL-TIME EMPLOYEES... 7 PART-TIME EMPLOYEES... 7 EMPLOYEE CHANGE OF STATUS... 8 REPORTING HOURS FOR CERTAIN EMPLOYEES... 8 PRIESTS... 8 RELIGIOUS ORDER PRIESTS OR LAY EMPLOYEES... 8 TEACHERS FULL-TIME... 9 TEACHERS PART-TIME FULL-TIME AT-WILL EMPLOYEE AGREEMENTS MUSICIANS COACHES/SEASONAL EMPLOYEES PART-TIME SALARIED WORKERS WORKING REMOTELY OR WORKING NON-STANDARD WORK-WEEKS SHARED EMPLOYEES REHIRED EMPLOYEES TIME SHEETS REVISITED ULTIPRO OR BAS GUIDE TO UPDATING THE EMPLOYER PROVIDED HEALTH INSURANCE OFFER & COVERAGE SPREADSHEET (HEALTH CARE WORKSHEET) AFTER APRIL 30, KEEPING YOUR HEALTH CARE WORKSHEET UP TO DATE EMPLOYEE HOUR CHART (FOR HEALTH CARE REPORTING) MONITORING ACTUAL HOURS WORKED ON-GOING EMPLOYEES NEW HIRES EXAMPLE ON-GOING FULL-TIME EMPLOYEE EXAMPLE NEW HIRE OF FULL-TIME EMPLOYEE EXAMPLE NEW HIRE OF PART-TIME EMPLOYEE ATTACHMENTS (LIST OF) Health Insurance Coverage & Reporting Issued July 2015 Page 2 of 20

3 INTRODUCTION BACKGROUND There has been a great deal of media coverage surrounding the Patient Protection and Affordable Care Act (PPACA), sometimes referred to as Obamacare or the Affordable Care Act. While much of the attention has focused on the constitutionality of the new health care law, the PPACA related Internal Revenue Code mandated reporting requirements remain in place. A team within the Plan Administrator 1 at the Archdiocese of Denver (AoD), in consultation with outside PPACA experts, has studied these mandated requirements and determined that they apply to all Participating Entities 2 in the Archdiocese of Denver Welfare Benefits Trust Self- Funded Medical Plan (AoD Medical Plan). Because of the structure of the Trust and its sponsored benefits plans, including the AoD Medical Plan, all of the Participating Entities in the AoD Medical Plan are considered members of what is termed an Aggregate Large Employer ( ALE ). All parishes located in the territory of the AoD, all parishes located in the territory of the Diocese of Colorado Springs ( DCS ), as well as select other related ecclesiastical entities, are all Participating Entities in the AoD Medical Plan, and therefore are considered ALE members. All ALE members of the AoD Medical Plan are required to comply with the new PPACA related Internal Revenue Code reporting requirements starting in calendar year As previously communicated, it is critically important that every ALE member continue tracking the information, as detailed in the Employer Provided Health Insurance Offer & Coverage spreadsheet, 3 (the Health Care Worksheet ) for calendar year Failure to comply will result in PPACA penalties. We understand the demands this information gathering places on ALE members. Due to the new PPACA 2015 requirements, we had to first ensure that all AoD Medical Plan eligible employees were offered medical coverage during Open Enrollment in 2015 (May June, 2015) 1 The Plan Administrator for the Archdiocese of Denver Welfare Benefits Trust (the Trust ) is the Archdiocese of Denver Management Corporation, a Colorado nonprofit corporation that was formed in part to provide such services. 2 Participating Entities in the AoD Medical Plan consist of the following: the AoD and the parishes located in the AoD territory; the Diocese of Colorado Springs ( DCS ) and the parishes located in the DCS territory; select other related ecclesiastical entities such as diocesan high schools, Catholic Charities in the AoD and DCS territories, the Catholic seminaries located in the AoD territory, and the Catholic cemeteries and the Catholic mortuary located in the AoD territory. 3 This was issued to parishes and other Participating Entities in the AoD territory only. Parishes and other Participating Entities in the DCS should consult the DCS HR Office to determine its method of information gathering. Health Insurance Coverage & Reporting Issued July 2015 Page 3 of 20

4 (this process included evaluating employees working for multiple ALE members). We must now continue monitoring employee hours for eligibility in order to be able to issue a new federal tax information return (1095-C). We appreciate and acknowledge the business managers who have stepped forward to tackle these new challenges Health Care Reporting and Tracking Hours Requirement Beginning with calendar year 2015, the Internal Revenue Code (IRC) requires all ALE members to provide each qualified full-time employee with the new Internal Revenue Service (IRS) Form 1095-C (similar to W-2 reporting). This form must also be filed with the IRS along with the new IRS Form 1094-C (the transmittal form). All ALE members must monitor and track employee hours to determine whether employees are working, on average, at least 30 hours per week (130 hours per month) and are therefore eligible for medical coverage under the AoD Medical Plan. The hours must be tracked for each full-time employee from January 1, 2015 December 31, If eligible, the employer must offer employees coverage and treat the qualifying employees as eligible for an associated (future) 12-month period of time (see Stability Period, defined later). Additionally, the Plan Administrator is required to count employees hours of service across all ALE members (i.e., shared employees). This will need to be performed annually to coincide with open enrollment Tracking and Reporting Tool AoD Participating Entities (DCS Participating Entities please refer to your DCS HR office) The Plan Administrator has designed an Excel Employer Provided Health Insurance Offer & Coverage spreadsheet (the Health Care Worksheet ) with a dual purpose: (1) to allow Participating Entities (all ALE members) to gather and track employee hours and gather other required information for 2015 year-end reporting, and (2) in the AoD locations, to allow the Plan Administrator to use the information to monitor and test shared employees. The Health Care Worksheet, instructions and support were previously provided. Time Table for Tracking Hours of Service Calendar Year Reporting Period January 1, 2015 through December 31, 2015 IRS Form 1095-C Reports are due to full-time employees by February 1, 2016 and to the IRS by March 31, 2016 for electronic filing. Monthly hours worked from January December are reported for each qualified employee. 4 Within the AoD, we are currently looking at standardizing payroll (for the parishes and AoD) in part as a way to more easily and accurately gather and monitor hours and prepare the annual information returns in the future. Health Insurance Coverage & Reporting Issued July 2015 Page 4 of 20

5 Standard Measurement Period Because of the timing of our pre-existing Open Enrollment period and the new PPACA requirements for 2015, there was an initial measurement period from January 1, 2015 April 30, This period preceded the 2015 Open Enrollment period. The initial measurement period was then followed by the new Standard Measurement Period of May 1, 2015 through April 30, 2016 Employee hours need to be tracked monthly for determination of health care coverage eligibility both now and in the future (the Standard Measurement Period is scheduled to coincide with the regular Open Enrollment period). Administrative Period May 1 through June 30, 2015 (Open Enrollment occurred during this period) Employee hours from the initial measurement period (January 1, 2015 April 30, 2015) were reviewed and tested for health care coverage eligibility. If eligible, the employee was offered health care coverage and other benefits. Stability Period July 1, 2015 through June 30, 2016 Employees who were determined to be eligible for health care coverage as full-time employees will be treated as eligible for the duration of this period even if their hours fall to less than 30 per week. The following, in general, summarizes the schedule for PPACA reporting and health care eligibility tracking for 2016 and the implications for 2017: All employee hours are tracked during the Stability Period (May 1, 2015 April 30, 2016). The hours tracked during the Stability Period will be used during the next Administrative Period (May 1, 2016 June 30, 2016) to ensure that all employees eligible for medical coverage have been offered coverage and are properly enrolled in coverage (if they choose coverage) during the Open Enrollment period (to take place in May and June of 2016, enrollment changes to be effective July 1, 2016). Employees that are determined to be eligible for medical coverage and have elected coverage are then enrolled in the AoD Medical Plan during the Stability Period of July 1, 2016 June 30, For IRS reporting purposes, reporting of health care coverage under the AoD Medical Plan will again require reporting over a calendar year (January 1, 2016 December 31, 2016). Reporting forms due to the IRS are to be electronically filed in February/March of Health Insurance Coverage & Reporting Issued July 2015 Page 5 of 20

6 WORKER CLASSIFICATION All workers of Participating Entities (all ALE members) must be properly classified. As a general rule, unless a worker qualifies as an independent contractor (very rare) or a bona fide volunteer, they are an employee. The employer is always responsible for determining proper classification based on the facts and circumstances of each situation, and for correcting misclassified workers. Classifying a worker as an independent contractor cannot be used to avoid payroll tax and benefit costs. Misclassification can result in penalties for the employer. Within the AoD locations, please refer to the Worker Classification Schedule (ver 3.0) posted on Ultipro and previously distributed, or contact Trina Moog or Pat Kaus with questions or for assistance to correct misclassified workers. EMPLOYEE CLASSIFICATION Employee positions must be properly classified as either Exempt or Non-Exempt in accordance with Federal and State employment laws. This status should be included in each employee s job description (and within the AoD, entered in UltiPro). Positions that qualify for Exempt status are typically paid on a salary basis and are not subject to overtime or minimum wage requirements. Employees who do not qualify for Exempt status are Non-Exempt, are typically paid on an hourly basis, and are subject to overtime and minimum wage requirements. STANDARD WORK WEEK Employers should define a standard work-week for (i) full-time employees, e.g., 40 hours per week, 37.5 hours per week, etc., and specified by days of the week, such as Monday-Friday, Sunday-Saturday, etc. (see Full-Time Employees, later), and (ii) for part-time Employees whose work week is less than full-time, e.g., 15 hours per week, 20 hours per week, etc. The defined work week should be included in the location s Employee Handbook and in the employee s job description. Health Insurance Coverage & Reporting Issued July 2015 Page 6 of 20

7 TIME SHEETS We appreciate the effort you have made to ensure all Non-Exempt employees report hours through time sheets, cards or electronically. Time sheets must reflect ACTUAL HOURS WORKED. Due to the PPACA reporting requirements beginning in 2015, it is more important than ever that these hours are MONITORED. The actual hours worked will now be used to calculate average hours worked to determine full-time status and eligibility for health care benefits and enrollment in the AoD Medical Plan. FULL-TIME EMPLOYEES Full-time employees are defined as those employees who work, on average, at least 30 or more hours per week (130 hours per month). Full-time employees are eligible for medical coverage and other benefits. Exempt full-time employees (salaried) are not required to submit a time sheet but are required to submit a time-off report. Non-Exempt full-time employees (hourly) are required to submit a time sheet. PART-TIME EMPLOYEES Part-time employees are defined as those employees who work, on average, less than 30 hours per week (130 hours per month). Part-time employees are not eligible for medical coverage and most other benefits. To ensure, in part, continued compliance with PPACA, all part-time employees (both hourly and salaried) are required to submit a time sheet. Even in the situation where the part-time employee is paid a salary for a defined number of house worked each week, the employee still must submit a time sheet and the employer must track the hours worked. Health Insurance Coverage & Reporting Issued July 2015 Page 7 of 20

8 EMPLOYEE CHANGE OF STATUS If an employer authorizes a change in an employee s status from part-time to full-time or the employee begins a new full-time position either at the same or with another Participating Entity (including multiple locations), the employee must be offered benefits on the date of the status change. Remember: without an employer authorized Change in Status, an employee's status will not change based on an increase in average hours worked until the next Standard Stability Period (during the Administrative Period, the average hours worked (during the Standard Measurement Period) are calculated and if any employees average hours exceed 130 hours per month, they will be offered coverage in the AoD Medical Plan for the next Standard Stability Period (July 1 June 30)). If an employee is authorized to change from full-time to part-time status, please refer to the separately issued Health Care Practice Notice #1 for instructions on how to handle this change for employees under teacher contracts (this Notice #1 applies to and was originally sent only to ALE members that are parishes with schools, or are stand-alone schools). Please refer to the separately issued Health Care Practice Notice #2 for how to treat all other employees (i.e., all employees not under a teacher contract). Note that both Health Care Notices #1 and #2 are attached to this Guide. REPORTING HOURS FOR CERTAIN EMPLOYEES Priests Full-time priests hours should be reported as hours per month. Report part-time priest hours as the hours scheduled provided they work less than 30 hours per week or less than 130 hours per month at your location. Religious Order Priests or lay employees Report Religious Order employee hours ONLY if they are full time and enrolled in the AoD Medical Plan EVEN THOUGH they are paid through accounts payable and do not receive a W-2. Participating Entities are required to report coverage for all individuals on the AoD Medical Plan. Payment for the services provided by members of Religious Orders is made payable to the Order itself. If members of Religious Orders are enrolled in their Order s medical plan, or some other plan, they should not be reported on the Health Care Worksheet or be included in ALE member reporting generally. Health Insurance Coverage & Reporting Issued July 2015 Page 8 of 20

9 Teachers Full-Time Report full-time teachers as hours per month; however, if the teacher contract specifies a lesser standard work week, such as 37.5 hours per week (162.5 hours per month), use the hours specified in the contract. In order to remain eligible for full-time benefits, hours should be imputed to the teacher (and therefore reported) during academic breaks (defined as summer break, Christmas break or spring break when the school is closed or inaccessible to the teacher) whether the teacher selects a 10-month or 12-month payout. This may result in reporting hours when no hours are actually worked or paid, but this is done so as to ensure the teacher remains eligible for fulltime status and is not improperly penalized for academic break periods. Note: within the AoD ALE member locations, use the official Office of Catholic Schools school calendar as your guide associated with academic breaks. Similarly, DCS school locations should consult the official Catholic School calendar for the DCS. For example, a 37.5 hour per week teacher will have hours reported each month (37.5 hours per week X 52 weeks / 12 months = hours per month). These hours will be reported for all months, including the time attributed to academic breaks, as long as the teacher is under contract or has renewed a contract for the subsequent school year. In the case of a full-time teacher, because their full-time hours already qualify them for health care eligibility, any hours paid for additional services (extra duty pay for example: coaching, supervising clubs or after school activities) may be, but are not required to be, reported for health care reporting purposes only. It is, however, highly recommended that these extra duty hours be recorded on a time sheet and approved by the appropriate supervisor(s) to ensure payroll records are accurate. Returning contracted teachers: Report contracted hours for every month including those with reduced or no hours of service due to academic breaks. For example, if a 40 hour per week teacher s contract is renewed for the following academic year, continue to report hours for June, July and August. Non-renewed contracted teachers: If the teacher contract is not renewed, stop recording contracted hours in June and instead report actual hours worked in June and no hours for July or August. Record their termination date on the Employee Information tab as the last day worked (for example, 6/5/2015) and mark coverage for June, July and August on the Employee Coverage tab if they are enrolled in the AoD Medical Plan. Please see Shared Employees, addressed later, for additional information on reporting full-time shared teachers on a contract. Health Insurance Coverage & Reporting Issued July 2015 Page 9 of 20

10 Teachers Part-Time Report part-time teachers as actual hours worked and reported on the employee time sheet. Any hours paid for additional services (extra duty pay, for example: coaching, supervising clubs or after school activities) must be reported and tracked on a time sheet (and monitored) to ensure the hours spent coaching or on other school related and compensated activities do not move the part-time teacher into full-time status. Full-Time At-Will Employee Agreements 5 (ELC teacher/aide/other salaried school non-teacher employee) Report full-time at-will employees hours throughout the year, including during academic breaks (defined as summer break, Christmas break, and spring break when the school is closed or inaccessible to school specific employees) in order to confirm eligibility for benefits. If the employee is returning in the following academic year, continue to report hours based on the employee s standard work week. This may result in reporting unpaid hours that were not reported on the employee s time sheet in order to ensure the employee remains eligible for full-time status. Within AoD ALE members, refer to the official Office of Catholic Schools school calendar as your guide to recording unpaid hours associated with academic breaks. Similarly, DCS school locations should consult the official Catholic School calendar for the DCS. For example, a 30 hour per week school administrative assistant will have 130 hours reported each month (30 hours per week X 52 weeks / 12 months = 130 hours per month). These hours will be reported for all months, including during academic breaks as long as the full-time at-will employee is under an at-will agreement or has renewed an at-will agreement for the subsequent school year. Returning at-will employees: Report agreed upon hours for every month including those with reduced or no hours of service due to academic breaks. For example, if a 30 hour per week atwill employee s agreement is renewed for the following academic year, continue to report 130 hours for summer break months of June, July and August. Non-renewed at-will employees: If the at-will agreement is not renewed, stop recording contracted hours in June (or their last day worked) and instead report actual hours worked (generally no hours for July or August). Record their termination date on the Employee Information tab Health Care Worksheet as the last day worked (for example, 6/5/2015) and 5 Reminder, at-will agreements are NOT employment contracts; rather, they are documents that simply reinforce the at-will nature of the employment relationship between the at-will employee and the employing school/parish, while also serving to define the time periods the worker is expected to work during the school s academic year, which of course is different from a typical worker year. Health Insurance Coverage & Reporting Issued July 2015 Page 10 of 20

11 mark coverage for June, July and August on the Employee Coverage tab if they are enrolled in the AoD Medical Plan. Musicians Report full-time musicians, such as an Exempt full-time music director, as actual hours worked or as days worked equivalency. Report part-time musicians as actual hours worked and reported on the employees time sheets, including practices, rehearsals, meetings and other administrative time. See also Part-time salaried worker below for further information on paying part-time employees based on a flat rate or per unit basis. Coaches/Seasonal Employees Seasonal employees are defined as an employee in a position for which the customary annual employment is six months or less, typically beginning in the same part of the year such as winter or summer. Report seasonal/coaching employees as actual hours worked on the employees time sheets, including practices and meetings or other administrative time. Treat seasonal employees as a new part-time employee, ineligible for benefits until the end of the 12-month initial measurement period, testing their average hours at the end of the 12- month initial measurement period. If average hours worked are 30 hours per week or more, offer benefits if they are still working at the end of the 12-month initial measurement period. Note: be careful, some coaching is not deemed seasonal depending on the nature of the services provided. In addition, the individual may serve in other positions at the same time as in a coaching position, or throughout the remainder of the year. Consult your respective HR Office at the AoD or DCS to clarify the proper treatment of a particular coach. Part-time salaried workers Time sheets showing actual hours worked are required to be submitted for ALL part-time employees for health care monitoring purposes even though part-time salaried workers will be paid a defined standard salary rather than on a per hour basis. When a part-time employee is paid a flat rate (like a salary), then additional work is required to ensure the employee is paid minimum wage, calculated as Flat Rate Salary / Hours Worked = Hourly Rate, which must be at least minimum wage. If the calculation of the hourly rate is less than minimum wage ($8.23 for 2015), increase the employee s pay to meet minimum wage requirements. Note that a part-time salaried worker s calculated hourly rate may fluctuate based on the number of hours they work to complete the agreed upon duties. They are not eligible for extra Health Insurance Coverage & Reporting Issued July 2015 Page 11 of 20

12 pay to perform the agree-upon duties unless, as noted above, the pay fails to meet minimum wage requirements. Working remotely or working non-standard work-weeks Like regularly scheduled employees, supervisors of employees who work away from the office (remotely) and/or work weekends and/or evening hours should communicate the hours expected to fulfill the job duties. Employees working remotely must report their hours worked to the Employer based on the full-time or part-time status of the employee as previously discussed. Shared Employees Report the hours worked at your location. Within the territory of the AoD, after all ALE members submitted their Health Care Worksheet (through April 30, 2015), the Worksheets of all Participating Entities were combined and sorted by Social Security Number (SSN) to find and measure employees who were found to work for multiple entities. If a worker is eligible for full-time status based on average hours worked, the AoD or DCS HR Offices will coordinate the offer of benefits with the affected Participating Entities. 6 Shared Employees on a Full-Time Teacher Contract: The location that pays for health care should report the employee as full-time, record their share of the employee s contracted hours (see the section entitled Teachers Full Time for a discussion of how to report contracted hours) and record the months the employee waived or was enrolled in the AoD Medical Plan. The ALE member location(s) that doesn t pay for the health coverage reports the employee as part-time, records their share of the employee s contracted hours, and does not complete the Employee Coverage of the Health Care Worksheet tab for this employee. These hours will be reported for every month the teacher remains employed, including during months with academic breaks. Report the same hours whether the teacher is paid over 10 or 12 months. For example, a full-time teacher is contracted to work 60% for Location 1 and 40% for Location 2. Location 1 will report 104 hours per month (40 hours per week X 60% = 24 hours per week X 52 weeks in a year / 12 months = 104 hours per month). Location 2 will report hours per month (40 hours per week X 40% = 16 hours per week X 52 weeks in a year / 12 months = hours per month). Note that the combined hours total to hours per month. Note on Allocated Employees: If one participating employer processes payroll for itself and one or more related entities, such as a mission or quasi-parish, and the employee costs are then allocated to that related entity, report all information through the employing parish (that is, through the parish that processes payroll and under whose EIN the payroll reports are filed). 6 The DCS and the AoD will be communicating with regard to workers for ALE members spread across the territory of both dioceses and are therefore shared employees and potentially eligible for medical coverage. Health Insurance Coverage & Reporting Issued July 2015 Page 12 of 20

13 Rehired Employees For instructions on how to treat employees who are terminated but rehired by the same or a different Participating Entity, please refer to the separately issued Health Care Practice Notice #3, which is attached to this Guide. Time Sheets Revisited Time Sheets are a critical payroll document. Time sheets reporting actual hours worked and paid time off are encouraged from all employees, however, Time Sheets are REQUIRED for the following employee classifications: Full-time Non-Exempt employees Part-time employees (even if they are paid a salary, per unit or a flat rate) Full-time shared school and non-school employees (report actual hours worked to each location) Seasonal employees Time Off Reports which report only paid time off (typically for sick, vacation or personal leave days depending on the employer s written paid time off plan) are required for Exempt employees including: Full-time Exempt employees (but not including Pastors or Parochial Vicars) Full-time school employees under a teacher contract Full-time at-will school employees We appreciate the time and effort that proper time reporting takes and appreciate your hard work to collect, process and file time sheets at your location. UltiPro or BAS So as to remain compliant with PPACA rules, remember to regularly UPDATE your UltiPro or BAS programs (as applicable, depending upon whether you re in the territory of the AoD or the DCS) with all employee and benefit information in a timely manner. This is especially true for new hires and for employee life changes. Health Insurance Coverage & Reporting Issued July 2015 Page 13 of 20

14 FOR AOD LOCATIONS: GUIDE TO UPDATING THE EMPLOYER PROVIDED HEALTH INSURANCE OFFER & COVERAGE SPREADSHEET ( HEALTH CARE WORKSHEETS ) AFTER APRIL 30, 2015 Thank you to all who completed the Health Care Worksheets for the months of January 2015 through April 2015 and submitted them by May 15 th. Your cooperation, time and effort are greatly appreciated! Now we must continue moving down this Health Care Worksheet road. The following instructions should help us all to navigate this road however if you have any questions or problems, please do not hesitate to (preferred) or call Pat Kaus at pat.kaus@archden.org or Trina Moog at trina.moog@archden.org KEEPING YOUR HEALTH CARE WORKSHEET UP TO DATE After the final payroll is run for each month, immediately update the Worksheet. This can be done in five steps that coincide with the five tabs in the worksheet: 1. Employer Information tab Update for changes (if any) to: a. Employer name and address b. Contact name, telephone and address 2. Employee Information tab a. New hires add contact info and hire date b. Terminations add termination date (but do not delete employee information) c. Life Changes add date and reason for life change d. Update for changes to contact information 3. Employee Hour tab a. Add hours for the current month b. Refer to previous instructions in this Guide and the Employee Hour Chart, below, for what hours to enter general rule is actual hours worked 4. Employee Coverage tab a. Add X s for full-time employees enrolled in the Health (Medical) Plan only do not report coverage in the dental, vision or life insurance plans 5. Dependent Coverage tab a. New dependents add name and social security number (or date of birth if SSN is not available) Add X s for dependents enrolled in the AoD Medical Plan only do not report coverage in the dental, vision or life insurance plans. Health Insurance Coverage & Reporting Issued July 2015 Page 14 of 20

15 EMPLOYEE HOUR CHART (FOR HEALTH CARE REPORTING) EMPLOYEE CATEGORY Full-time Exempt Full-time Non-Exempt Full-time Contracted School Teacher Full-time At-Will School Employee Part-time Employee hourly Part-time Employee salaried/flat rage HOUR MEASUREMENT METHOD Actual hours worked including paid time off or days-worked equivalency (see below) * Actual hours worked including paid time off Contracted hours reported consistently without regard to time off during academic breaks See Reporting Hours for Certain Employees/Teachers Full-Time for details on how to report hours for returning teachers and non-renewed contracts Agreed-upon hours reported consistently without regard to time off during academic breaks See Reporting Hours for Certain Employees/Full-Time At Will Employee Agreements for details on how to report hours for returning at-will and non-renewed agreements Actual hours worked only Actual hours worked only * DAYS WORKED EQUIVALENCY Days-worked equivalency uses a flat 8 hours per day (40 per week or per month) but can be adjusted to reflect the true hours that a full-time employee is providing, anywhere from 30 hours per week through 40 hours per week. For example you can use these rates for a fulltime employee with the following typical work weeks: Days-worked Equivalency Chart for Full-time Exempt Employees Hours per Day Hours per Week Hours per Month 6 hours 30 hours 130 hours 6.4 hours 32 hours hours 7 hours 35 hours hours 7.5 hours 37.5 hours hours Health Insurance Coverage & Reporting Issued July 2015 Page 15 of 20

16 MONITORING ACTUAL HOURS WORKED While entering hours into the Employee Hours tab of the worksheet, the employer has the opportunity to monitor employee hours. This allows the employer to ensure that the employee works their agreed upon hours. While an employee s status as full-time or part-time generally cannot be changed during a Stability Period without an authorized Change in Status, a part-time employee s status will change to full-time if actual hours worked over the 12-month Standard Measurement Period equal or exceed the 130 hour minimum. In the same way, a full-time employee s status will change to part-time if actual hours worked over the 12-month measurement period fall below the 130 hour minimum. Careful monitoring of employee hours during the Standard Measurement Period allows the employer to manage the employee hours and the financial impact of a Change in Status. ON-GOING EMPLOYEES On-Going Employees are initially those employees who are employed as of July 1, Thereafter, on-going employees are those employees who have completed a full 12-month initial measurement period starting on their date of hire. During the Standard Stability Period beginning July 1, 2015 and continuing through June 30, 2016, employees identified as full-time (i.e., defined as those working 30 or more hours per week) will continue to be eligible for medical coverage unless an authorized Change in Status to part-time or a termination occurs. During this same period, part-time employees (defined as those working less than 30 hours per week) will continue to be ineligible for medical coverage unless an authorized Change in Status to full-time occurs. REFER TO HEALTH CARE PRACTICE NOTICES 1 AND 2 FOR HOW TO HANDLE CHANGE IN STATUS, DEPENDING ON WHETHER THE EMPLOYEE IS A TEACHER IN OUR SCHOOLS UNDER CONTRACT (Notice #1), OR A NONTEACHER EMPLOYEE (Notice #2) Health Insurance Coverage & Reporting Issued July 2015 Page 16 of 20

17 NEW HIRES Employees hired on or after May 1, 2015 will begin an initial measurement period starting on their hire date which will continue for twelve months through the day before their first anniversary date of their employment. Newly hired employees expected to work full-time hours will be offered medical coverage on their date of hire. If enrolled, this coverage cannot be terminated until the employee completes their entire twelve-month initial measurement period (or in the event the newly hired employee terminates employment). Newly hired employees expected to work part-time hours will not be offered health care coverage unless there is an authorized Change in Status to full-time. On or up to 60 days after the newly hired employee s first anniversary date, the employee s initial administrative period begins. The employer will calculate the average monthly hours that the employee actually worked (or use days worked equivalency for full-time Exempt employees and full-time contracted or at-will school employees) over the 12-month initial measurement period. If the employee averages 130 or more monthly hours, the employee will continue health care coverage or be offered health care coverage if not already enrolled. If the employee averages less than 130 monthly hours, the employee will not be offered health care coverage or their health care coverage will terminate. The employee s full-time or part-time status will continue during the entire twelve-month initial stability period, which begins immediately following the initial measurement period and related initial administrative period. Special Rule for Initial Full-Time Status employee must continue to be treated as full-time through the end of the employee s initial stability period even if average hours during the employee s first standard measurement period drop below 30 hours per week. In this case, the employee will convert to part-time status once the first standard measurement period is complete, their average hours drop below 30 per week and they become ineligible for health care coverage. Special Rule for Initial Part-Time Status employee status must change to full-time at the beginning of the next Standard Stability Period if the employee s first standard measurement period results in average hours of 30 or more per week, even if the start of the next Standard Stability Period begins before the end of the initial stability period. New employees transition into the Standard Measurement and Stability Periods used by ongoing employees, typically requiring certain months to be counted twice for the initial and the first standard measurement period. Health Insurance Coverage & Reporting Issued July 2015 Page 17 of 20

18 EXAMPLE ON-GOING FULL-TIME EMPLOYEE FACTS: Employee hired 6/5/2010 as a full-time 40-hour-per-week employee, who was offered and enrolled as an individual in the AoD Medical Plan. The employee has not experienced, and will not experience, any Change in Status, and has continued to provide 40 hours of service per week. First standard stability period July 1, June 30, The employee will continue to be eligible for health care coverage. First standard measurement period - May 1, 2015 April 30, 2016 The employer updates the Health Care Worksheet for employee s hours (use for each month worked). The employer also updates the employee coverage by marking an X in each month worked. First standard administrative period May 1, 2016 June 30, 2016 The employer calculates the employee s average hours over the first standard measurement period. This employee will average hours and continue to qualify as a full-time employee eligible for health care coverage. Employer will submit spreadsheet to Parish Finance in order to identify shared employees who qualify for health care coverage based on average hours worked at all locations. Second standard stability period July 1, 2016 June 30, 2017 The employee will continue to be offered health care coverage. EXAMPLE NEW HIRE OF FULL-TIME EMPLOYEE See Attachment 4 FACTS: Employee hired 6/5/2015 as a full-time 40-hour-per-week employee, who was offered and enrolled as an individual in the AoD Medical Plan. The employee is not expected to experience any Change in Status, and is expected to continue to provide 40 hours of service per week. Initial measurement period - June 5, 2015 June 4, 2016 On the Health Care Worksheet, the employer enters the employee information and records the employee s hours (use for each month worked). The employer also records the employee coverage by marking an X in each month worked. The employee will continue to be offered health care coverage through the end of the initial measurement period and the related initial administrative period. Initial administrative period June 5, 2016 August 31, 2016 (88 days) The employer calculates the employee s average hours over their initial measurement period. This employee will average hours and continue to qualify as a full-time employee eligible for health care coverage. Note that this administrative period is longer than the standard administrative Health Insurance Coverage & Reporting Issued July 2015 Page 18 of 20

19 period of 61 days, but still less than the maximum allowed of 90 days to allow for transition from months with less than full calendar days to full calendar months. Initial stability period September 1, 2016 August 31, 2017 The employee will continue to be offered health care coverage through the last day of the initial stability period, even if hours drop below 30 per week. See Health Care Practice Notice #2, Scenario II for further information on Change in Status rules for new employees. Note that while measurement periods and the associated administrative period need not be based on calendar months, a stability period, in contrast, must be based on calendar months. Transition to standard measurement period May 1, 2016 April 30, 2017 The employee s hours will be recorded twice, once for the initial measurement period and again for the employee s first standard measurement period for the months of May through August The employee s first standard administrative period will be May 1, 2017 June 30, The employee s first standard stability period will be July 1, 2017 June 30, EXAMPLE NEW HIRE OF PART-TIME EMPLOYEE See Attachment 5 FACTS: Employee hired 6/5/2015 as a part-time 20-hour-per-week employee. The employee is not expected to experience any Change in Status, and is expected to continue to provide 20 hours of service per week. Initial measurement period June 5, 2015 June 4, 2016 On the Health Care Worksheet, the employer enters the employee information and records the employee s actual hours worked based on time sheets. The employee will not be offered health care coverage through the end of the initial measurement period and the related initial administrative period. Initial administrative period June 5, 2016 August 31, 2016 (88 days) The employer calculates the employee s average hours over the initial twelve-month measurement period. If the employee averages less than 30 hours per week the employee will continue to be ineligible for health care coverage. If the employee averages 30 or more hours per week, the employee should be offered health care coverage during the initial administrative period with an effective date of September 1, Initial stability period September 1, 2016 August 31, 2017 The employee averages 104 hours per month (24 hours per week), therefore the employee will continue to be ineligible for health care coverage through the last day of the initial stability period. Transition to standard measurement period May 1, 2016 April 30, 2017 The employee s hours will be recorded twice, once for the initial measurement period and again for the employee s first standard measurement period for May through August The employee s Health Insurance Coverage & Reporting Issued July 2015 Page 19 of 20

20 first standard administrative period will be May 1, 2017 June 30, The employee s first standard stability period will be July 1, 2017 June 30, Transition to standard stability period July 1, 2017 through June 30, 2018 A special rule for new part-time employees requires the employer to change the employee s status to full-time at the next standard stability period if the first standard measurement period results in average hours of 30 or more per week, even if the next standard stability period begins before the end of the initial stability period. Therefore, in this example, the employer would measure the employee s hours during the standard administrative period beginning May 1, 2017 through June 30, If the employee s average hours result in 30 or more hours per week (130 or more hours per month) then the employer must offer health coverage effective July 1, 2017, two months before the end of the initial stability period. Attachments 1. Health Care Practice Notice #1 Change of Status for Teachers Under Contract only 2. Health Care Practice Notice #2 Change of Status for Employees other than Teachers under Contract 3. Health Care Practice Notice #3 Medical Coverage Requirements for Shared Employees and/or Employees Moving from One Employer to another Employer (Hire/Rehire Rules) 4. Health Care Periods Overview New Full-Time Employee Example 5. Health Care Periods Overview New Part-Time Employee Example Health Insurance Coverage & Reporting Issued July 2015 Page 20 of 20