Health Insurance Eligibility

Operational Standard/Purpose

The Affordable Care Act (ACA) mandates that, beginning January 1, 2014, employers with 50 or more full-time employees to offer health coverage to those employees. The ACA classifies employees as “full-time” employees if they work at least thirty (30) hours per week on average or 130 hours of service as the monthly equivalent of 30 hours of service per week.

In compliance with the Affordable Care Act (ACA), ICC tracks the full-time equivalency (FTE) of all employees.

Scope/Applicability

Refer to the Employee Handbook for additional information.

Procedures

1. Human Resources Department Places Employee into Appropriate Category: For purposes of determining whether someone is a full-time employee, employees are categorized as:
   1. Ongoing employees: a worker who has been employed for a year or more.
   2. New full-time employees: Newly hired employees who are reasonably expected to work full-time. Employees who are expected to work full-time at the time of hire, qualify immediately as full-time, and should be offered health coverage with no more than a 90-day waiting period (temporary full-time employees). The initial measurement period for new variable-hour employees can start on the employee’s first day of work or shortly thereafter (start of the week, month or pay period).
   3. Seasonal or variable-hour employees: Employees in positions for which the customary annual employment is six months or less generally will not be considered full-time employees. Employees are variable hour employees when it cannot be determined at the time of hire whether a new employee is expected to work full-time or if an employee’s full-time status is reasonably expected to be of limited duration.
   4. Students (work study/non-work study): For the purpose of this procedure, all student workers have their clock hours limited to a maximum of 29 hours per week. Where hours exceed 29 per week due to holding multiple jobs, the student worker will be asked to resign from his/her secondary position.
   5. Assistant Coaches: Employees are treated as hourly workers requiring all hours for all jobs worked to be counted.
   6. Retired Part-time (Adjunct) Faculty: Retired part-time (adjunct) faculty will have FTE calculated at 2.25 hours of service per week. In addition, a secondary review of potential earnings to the allowable earnings cap will be calculated to ensure that both earnings and contact hours are below their respective regulatory and policy ceilings.
2. Verify Full-Time Equivalency (FTE): ICC verifies FTE using the look-back measurement to determine employee FTE. The look-back period (referred to as the stability period), is based upon the hours of service of the employee in a prior period (referred to as the measurement period). ICC does not take into account the potential for, or likelihood of, an employment break period in determining hours of service when calculating FTE. If, after the measurement period, an individual is determined to have worked for an average of thirty (30) or more hours per week, they must be offered coverage prospectively.
3. Determining FTE of Part-Time (Adjunct) Faculty: ICC uses the Safe Harbor method for determining the FTE of part-time (Adjunct) faculty. FTE for this employment group is calculated by using the safe harbor rate of 2.25 work hours for every part-time (adjunct) contact hour. Example: A part-time (adjunct) faculty taught 13 credit hours (ECH) in a semester and had no other required responsibilities. The FTE calculation would be 13 ECH x 2.25 = 29.25 hours. Consequently, an institution would not be required to offer coverage under the ACA.
   1. Each term, the Human Resources Department will produce a report that looks back on part-time (adjunct) faculty work hours. A report detailing exceptions to the maximum contact hour will be submitted to the Vice President, Academic Affairs for review and approval. Any exceptions to the hours that have been approved by the Vice President, Academic Affairs are forwarded to the Human Resources Department for inclusion into the total report.
   2. Once per quarter, Human Resources will conduct an internal review of the prior quarter’s contact hours by adjunct faculty. Every July 1st, an annual review will be conducted for the purposes of establishing a “measurement” period and reporting to full-time employee status determinations.+
4. Monthly FTE Report: Benefits, Leaves, and Safety & Risk Management runs a monthly report to monitor the hours of service. One hundred thirty (130) hours of service in a calendar month is treated as the equivalent of at least 30 hours of service per week.
   1. Salaried Employees: An hour of service means each hour for which an employee is paid, or entitled to payment, for the performance of duties for the employer, and each hour for which an employee is paid, or entitled to payment, for a period of time during which no duties are performed due to vacation, holiday, illness, incapacity (including disability), layoff, jury duty, military duty or leave of absence. (Up to a maximum of 160 hours for any continuous period).
   2. Hourly Employees: For hourly employees, hours of service must be tracked on an actual hour basis.
   3. ICC reports employee FTE to the IRS annually.
5. On-Going Tracking: ICC continually tracks the FTE of employees using the following methods:
   1. New Hire Measurement Period - from Hire Date to Anniversary Date;
   2. Ongoing employees - track part-time and adjunct hours on a monthly basis;
   3. Seasonable employees – track on monthly basis to ensure assignment limits are adhered;
   4. Administrative Period – within 30 days after end of measurement period;
   5. Stability Period – Next 12 months.