1. We have a temp that has been working for us since October 1, 2013. She has averaged over 30 hours a week. She is taking her 32-day break in service in September, 2013. We plan to rehire her back on October 15, 2014 at only 20 hours per week. Is she eligible for ACA health insurance in 2015?
Yes. WSSU initial measurement period is September 1, 2013-September 30, 2014. Since this temp averaged over 30 hours/week over the initial measurement period, and if rehired, she will have to be offered employer-paid health insurance and coverage could begin January 1, 2015. If coverage was elected, the department would be billed for the monthly premium (currently $448.12/month). This temp would be eligible for up to twelve months of health coverage, regardless of hours worked each week. If the temp were not rehired back or employment ended by December 31, 2014, there would be no obligation to offer health insurance.
2. Our department wants to hire a temp in January, 2015. If we hire someone at 20 hours per week or less, do we still have to pay anything for health coverage under the ACA?
Maybe. If you hired someone who has never worked at WSSU or within the UNC System, you would be safe in not having to pay for health coverage under the ACA. However, if your temp is hired in another job on campus for say 12 hours a week in addition to your 20 hours a week, this may trigger ACA health coverage eligibility. At this point, your department might be on the hook for up to 2/3 of the cost of health coverage.
3. We want to hire a temp employee in January, 2015, but only work them for 25 hours a week. We do not have the money in our budget to pay for health insurance. Are we okay doing this?
Maybe. As in the situation in Scenario 2, other jobs/hours, could impact eligibility. It is also very important to realize that if the person you hire has worked at the University/UNC System in any capacity in the last 12 months (measurement period), this may also impact ACA health coverage eligibility due to the break in service rules and standard measurement periods.
1. Our office always hires students under the Work Study program. Does this have any impact on ACA health eligibility?
No. The ACA rules actually exempt Federal and State Work Study program hours from the ACA eligibility rules.
2. We have a grad student that works for us part-time. He may have a grad appointment as well. Since he has health coverage under the Graduate Student Support Plan (GSSP), we do not have to worry about ACA health coverage, right?
No, you will need to be concerned about this. The Graduate School has certain rules for WSSU employment for graduate students. You will want to consult with them on this. The GSSP does not meet the ACA rules for employer-provided health coverage. Realize that if you hire someone that is on a .5 FTE (20 hours/week) appointment and your office has hired him for 10 hours/week for the semester, this person is eligible for ACA health coverage. ACA health coverage is through the State Health Plan and the GSSP has no impact on this. The HR Benefits Office would have to offer this person the State Health Plan coverage. If accepted, your department would be responsible for all or a portion of the monthly cost.
Non-Tenure Track Faculty/Lecturers
1. We typically hire lecturers to teach 3 or 4 classes on a semester to semester contract. We have never had to pay benefits for these positions. Is that changing under the new ACA law?
Yes. Under the ACA law we now look at those newly hired who work 30 hours or more per week for 3 months or more as ACA health coverage eligible. A semester lasts more than 3 months. Next, you would have to look at the hours the person works. Under the UNC System rules, you must assign 3 hours of work effort for every 1 hour taught. Thus, someone teaching one 3-hour class would have 9 work hours of effort. Teaching three, 3-hour classes, would equate to 27 hours. Those teaching four or more classes might be ACA health coverage eligible.
2. We want to hire someone to teach two online classes each semester. This seems to equal only 18 hours/week of work effort and is below the 30-hour threshold. It seems this person would not be eligible for ACA health coverage.
Maybe. If this is the only job that the person is working in currently for WSSU or the UNC System, you are assuming correctly. However, what if this person is also teaching at NC Central University in Durham? You would have to combine all FTE/work hours to test for ACA health eligibility. If teaching two classes for WSSU and two classes for NC Central, this person is ACA health coverage eligibility. Your department could be liable for half the monthly cost of health coverage as the UNC System is the control group for ACA eligibility.