AFFORDABLE CARE ACT FEDERAL MANDATE FOR MEDICAL COVERAGE
The Affordable Care Act (ACA) is federal legislation intended to ensure that all Americans have access to medical insurance they can afford, whether the insurance is obtained from an employer, an insurance provider or the government marketplace. This law requires employers that have 50 or more full-time employees to offer medical insurance to full-time employees who average 30 or more work hours per week.
Wright State University already offers medical insurance to its continuing benefit eligible employees who work a minimum of 51% full-time equivalent hours (FTE). Therefore, for Wright State University’s traditional workers, we are well within the requirements of the ACA legislation. Traditional workers include classified, faculty and unclassified employees.
Wright State University also provides employment opportunities to several non-traditional workers, such as adjuncts and student employees. Graduate assistantships although not employment arrangements but rather financial support for full-time graduate students whose primary “job” is pursuing their degree, are also included. In the past, these groups have not been eligible for medical insurance.
Effective January 1, 2015, the ACA legislation requires Wright State to offer medical benefits to those non-traditional employees who average 30 or more work hours per week. Therefore, Wright State has developed policies and practices that ensure compliance with the Affordable Care Act. These guidelines establish calculations for hours worked to enable Wright State to determine whether or not these employees achieve or exceed the 30 hour average work limit. Hours worked for adjuncts will be based on credit hours taught, student employees will continue to document their actual hours worked, and graduate assistantships will list the hours per week within their contracts. The expectation for hours worked for these non-traditional groups will be less than the ACA mandated 30 or more hours and therefore, these non-traditional employees will continue to remain not eligible for medical insurance.
For more detail on these policies for non-traditional employees, please reference the following links:
Hours Worked Review for Non-Benefit Eligible
For the non-traditional employees and for part-time classified, faculty and unclassified employees (FTE less than 51%), the Affordable Care Act has established regulations for employers to periodically review their work hours to ensure an ongoing offering of medical coverage for those who qualify whenever the 30 or more work hours is obtained. Therefore, Wright State has established the following two measurement periods for these employees.
- Initial Measurement Period
- The average “hours worked” will be calculated for each new hire or rehire’ s first 11 months of employment, followed by a two-month administration period. Anyone who averages 30 or more hours over this timeline will be offered medical insurance effective for the next 12-month period. The initial measurement period will begin with the calendar month in which the hire worked the first day. For example, if beginning work on August 1, the 12-month initial measurement period will begin August. If the hire date is August 2, the 12-month initial measurement period will begin September.
Look-Back Period: First 11 Months of Employment
Administration Period: 2 Months
Benefit Period: 12 Months
- Standard Measurement Period
- Annually, the “hours worked” for these employees will be calculated for a fixed 12-month period, followed by a 90-day administration period. Anyone who averages the 30 or more hours worked over this timeline will be offered medical insurance the next 12-month period. The standard measurement period will be the 12-month period from October 3 to October 2; followed by the 90-day administration period with benefits beginning January 1.
Look-Back Period: 12 Months
Administration Period: 90 Days
Benefit Period: 12 Months
- Additional Considerations
- Measurement periods for current biweekly employees will consist of 26 pay periods falling within the October 3 through October 2 look-back period.
- Measurement periods for current salary employees will consist of 12 pay periods falling within the October 3 through October 2 look-back period.
- If someone works in more than one job classification, the hours worked will be combined for the calculations in the above mentioned measurement periods.
- For student employees, ACA allow work study hours to be excluded from hours worked; thus removed from consideration.
- If an exception to Wright State’s policy occurs at hire, the non-traditional employee may become medical eligible at day of hire, assuming full-time status and the length of service will exceed 90 days.
Offering of Medical Insurance
Anyone achieving the ACA established 30 or more hours average during either of the above two measurement periods will be offered medical insurance for themselves and/or their eligible dependent child(ren) during the administration period for a full 12-month period. Per ACA, a dependent is defined as a child of an employee who has not obtained age 26; ACA does not require employers to offer spouse or partner coverage.
The medical offering will be the Wright State University’s High Deductible Health Plan (HDHP) with the choice of Employee Only or Employee + Dependent(s) coverage. Plan design and premiums are subject to change annually and will be communicated via email to those who become ACA benefit eligible. This HDHP offering meets the ACA requirement of providing minimum essential coverage and affordability.
These ACA eligible employees will need to “elect” or “waive” coverage. For elections, premiums will be collected as equal “pre-tax” payroll deductions throughout the 12-month coverage period. Should the premium be greater than the amount of the paycheck, the non-traditional employee must make an “after-tax” payment to be received in Human Resources in a timely manner. Premium payments not received in full within 60 days of the beginning of a month, will result in cancellation of the elected medical insurance. For example, if premiums for the month of May are not fully paid by the end of June, medical coverage will be cancelled as of April 30.
Any questions or further clarification can be obtained by contacting Human Resources at firstname.lastname@example.org.