Transcript Affordable Care Act Shared Responsibility Mandate

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The Affordable Care Act (ACA)
Shared Responsibility Mandate
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Shared Responsibility
Mandate
 If employer offers coverage, must be offered to 95% of fulltime employees
 Must be Affordable
 Must meet Minimum Value Standards
 Use Safe Harbor guidelines to determine track time of
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Coverage
 Defined as:
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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
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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
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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
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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
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Tracking Time Worked
- initially all employees not offered
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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
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Example Tracking Periods
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Reporting
 Employers are required to report their employer provided
health coverage data to the Federal Government
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Three Major Impacts
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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
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Final Guidance Released
February 10, 2014
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 Further Guidance on types of employees and hours of
service
 2015 Transition Tracking Period Provisions
 Transitional 6 month tracking period
 Must begin
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Definitions from Guidance
 Seasonal
 Variable Hour
 Adjunct Faculty
 Rehired employees
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Student Employees
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Proposed Definition of
Student Employees
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 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
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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
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Send suggestions/comments to VPAA
listserv
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