December 6, 2013 by Bill Enright
Even though the Affordable Care Act (ACA) Pay or Play Penalty has been postponed until January 1, 2015, it doesn’t mean we get a one-year break from the other healthcare reform mandates and planning! Rather, now is the time to stick to your plan and follow your timetable.
In 2014, it is important that you continue to identify those part-time and variable employees who are working 30 hours or more including substitute teachers, those who job share, bus drivers, coaches, referees, seasonal workers and more. Why now? Because the ACA requires you to establish a “look back period”.
2014 is your “Look-Back Period”
School districts are urged to initiate a 12-month “look back period” starting January 1, 2014 in order to be ready for full compliance by the new Pay or Play rollout in 2015. That means tracking hours. If you don’t already have a way of tracking and documenting all employees’ hours, including substitutes and seasonal employees, start now. Without a tracking system, an employee that works one hour a day could be determined to work an eight hour day under the ACA definition of full-time.
Having this information will make compliance with the new mandates easier and more efficient. Employers will be penalized if they don’t offer minimum essential coverage to “substantially all” full-time employees and dependents in 2015 and affordable coverage to all employees working 30 or more hours.
For more information about the “look back period”, see the side bar on our article “Substitute Teachers in School Districts: How to Handle the PPACA Mandate to Offer Health Insurance to Employees Working 30 Hours Per Week“
For hour management considerations, see “Hour Management Considerations“