A past issue of PPACA Watch discussed how to determine if substitute teachers are considered full-time employees under the Affordable Care Act (ACA). But what about other staff who may work 30 hours during the school year, and may or may not work during the summer break? ACA has a special rule for educational organizations like yours. Not being aware of this special rule may cause a failure to identify full-time employees, potentially triggering a penalty.
Applying this special rule and other provisions of ACA may increase your costs. The first step to mitigate these potential cost increases is to determine which employees you will be required to offer “Affordable” health insurance coverage. Only after that can you determine which savings strategies to put in place.
A Special Rule For School Districts
ACA defines a full-time employee as one that is expected to work 30 hours or more per week (or average 130 hours a month) for a minimum of 120 days in a year. However, for educational organizations, there is a special rule that takes into account breaks of at least four consecutive weeks, such as summer vacation. Therefore, school districts must either exclude summer vacation when determining average hours or consider “crediting” employees with average hours during the break for purposes of determining full-time status.
Any employee who works or is expected to work 30 hours or more per week for nine months during the school year should be considered a full-time employee and must be offered affordable health insurance coverage.
Using the Look-Back Method to Identify Full-Time Employees
The Look-Back Method was introduced as a “safe-harbor” to help employers determine eligibility under the 30-hour mandate.
For more information, download our Legislative Brief: Identifying Full-Time Employees or visit http://www.groom.com/resources-734.html