Affordable Care Act Eligibility

Under the Affordable Care Act (ACA), the university is required to offer medical plan coverage to employees who do not otherwise meet the eligibility requirements of the university’s medical plan (“non-health benefits eligible employees”) if they work an average minimum of 30 paid hours per week during a look-back measurement period. Non-health benefits eligible employees who meet the ACA requirements are referred to on this page as “ACA Eligible Employees.”

ACA Eligible Employees are eligible for medical coverage at part-time rates. Although not required by the ACA, the university also offers ACA Eligible Employees dental and vision coverage at full cost. ACA Eligible Employees who enroll in medical, dental and/or vision coverage will receive monthly invoices for the required monthly contributions at their home address from HealthEquity/WageWorks. The ACA Eligible Employee must make the required premium contributions by the due date on the invoice or coverage may be terminated for non-payment.

A non-health benefits eligible employee will have an initial look-back measurement period that starts as of their hire date and ends 12 months later. This initial look-back measurement period also applies to any former employee, excluding any retiree, who is rehired as a non-health benefits eligible employee more than 26 weeks after their termination date. Subsequent annual measurement periods will begin on each October 3 and end on October 2 of the following year.

Note: Eligibility for ACA coverage is determined each year. Meeting the annual measurement period for a calendar year does not guarantee coverage for future years. See the examples below for additional information.

Examples:

New hires/rehires

Two examples:

1. A non-health benefits eligible employee hired on April 19, 2022, will have an initial look-back measurement period that begins on April 19, 2022, and ends on April 18, 2023. If the employee works an average minimum of 30 paid hours per week during this initial look-back measurement period, they will be eligible to enroll in one of the university’s medical plan options at the part-time premium rates and in the university’s dental and/or vision plan at the full cost with coverage effective beginning April 19, 2023, for the remainder of the 2023 calendar year through April 18, 2024. If the employee also met the average minimum paid hours during the annual look-back measurement period that started on October 3, 2022, and ended on October 2, 2023, their coverage will continue through the end of 2024 provided they remain employed by the university and make the required contributions to HealthEquity/WageWorks in a timely manner. If they did not meet the average minimum paid hours requirement during the annual look-back measurement period, their health coverage will end on April 30, 2024. In either case, to be eligible for the 2025 calendar year, the employee will have to meet the average minimum paid hours’ requirement for the annual look-back measurement period starting October 3, 2023, through October 2, 2024.
2. A non-health benefits eligible employee hired on November 15, 2022, will have an initial look-back measurement period that begins on November 15, 2022, and ends on November 14, 2023. If the employee works an average minimum of 30 paid hours per week during this initial look-back measurement period, they will be eligible to enroll in one of the university’s medical plan options at the part-time premium rates and in the university’s dental and/or vision plan at the full cost with coverage effective November 15, 2023, for the remainder of the 2023 calendar year through December 31, 2024, provided they remain employed by the university and make the required contributions to HealthEquity/WageWorks in a timely manner. To be eligible for the 2025 calendar year, they will have to meet the average minimum paid hours requirement for the annual look-back measurement period starting October 3, 2023, through October 2, 2024.

In both examples, for future calendar years, the employee’s look-back measurement period will follow the university’s annual look-back measurement period (October 3 through October 2). 

Transfers to a non-health benefits eligible role

An employee who:

• Meets the eligibility requirements of the medical plan; and 
• Transfers to a role as a non-health benefits eligible employee; and
• Has not met the requirements for retirement; and 
• Met the average minimum paid hours requirement during the annual or initial look-back measurement period applicable to them, 

will be an ACA Eligible Employee and eligible to continue medical coverage at part-time rates and dental and vision coverage at the full cost for the remainder of that calendar year provided they remain employed by the university and make the required contributions to HealthEquity/WageWorks in a timely manner. All other health and insurance benefits will end as of the end of the month in which they transfer to a role as a non-health benefits eligible employee.

For the following calendar year, the employee will be eligible for medical, dental and vision coverage if they meet the average minimum paid hours requirement during the annual look-back measurement period that ends after the date of transfer.

Two examples:

1. A full-time staff employee who was hired in 2016 transfers to a role as a non-health benefits eligible employee on May 15, 2024. Since the employee met the average minimum paid hours requirement during the annual look-back measurement period that ended on October 2, 2023, the employee will be eligible to continue medical coverage at part-time premium rates and dental and vision coverage at full cost for the remainder of 2024. Within 31 days following the date of transfer, the employee may elect to retain their current medical, dental and vision coverage options, change to a different medical and/or vision option or drop their coverage. If the employee elects medical, dental and/or vision coverage, they will receive monthly invoices for the required monthly contributions at their home address from HealthEquity/WageWorks. They must make the required premium contributions by the due date on the invoice or coverage may be terminated for non-payment. The employee’s other active health and insurance coverage will end on May 31, 2024.

For the 2025 calendar year, the transferred employee has an annual look-back measurement period that began on October 3, 2023, and ends on October 2, 2024. If the employee works an average minimum of 30 paid hours per week during this annual look-back measurement period, they will be eligible to enroll in medical, dental and/or vision coverage for the 2025 calendar year provided they remain employed by the university and make the required contributions to HealthEquity/WageWorks in a timely manner. 

2. A part-time staff employee who was hired in 2020 and whose scheduled weekly hours on their job record is 20 hours per week and who worked on average 20 hours per week transfers to a role as a non-health benefits eligible employee on April 15, 2024. In this case, the employee did not meet the average minimum paid hours requirement for ACA coverage during the annual look-back measurement period that ended on October 2, 2023. As a result, the employee’s active health and insurance coverage will end on April 30, 2024, and they may be eligible to elect COBRA for some benefits.

As in the example above, to be eligible for ACA health coverage in 2025, the transferred employee must meet the average minimum of 30 paid hours per week during the annual look-back measurement period that began on October 3, 2023, and ends on October 2, 2024.

The following chart summarizes how the university determines ACA eligibility:

Population Measured for ACA Eligibility	Part-time employees with scheduled weekly hours on their job record that are less than 20 hours per week, including adjuncts, and all temporary employees; measurement begins when they are hired or transferred into a role with scheduled weekly hours of less than 20 hours. If an employee with scheduled weekly hours of 20 or more transfers to a role with scheduled weekly hours on their job record that are less than 20, hours paid during the applicable measurement period will be counted to determine if the employee is eligible for ACA coverage beginning as of the first day of the month following the date of transfer.
Average Hours for ACA Eligibility	30 hours paid per week
Standard Measurement Period	10/3– 10/2 Measurement period is a one-year period from October 3 of the current year to October 2 of the following year. Both the standard and initial measurement periods are on a 12-month “look back” measurement method to determine the weekly average hours paid.
Stability Period	Calendar year If a non-health benefits eligible employee meets the average hours paid requirement during the standard measurement period, they become eligible for health care coverage effective January 1 of the following calendar year regardless of the hours worked during that calendar year.
New Hire Initial Measurement Period	From date of hire in a role as a non-health benefits eligible employee to one-year anniversary of hire date Weekly average hours paid completed by the new employee during the initial measurement period are measured to determine ACA eligibility.
When ACA Eligibility (Coverage) Begins	New Hires or Rehires after 26 weeks:  If they have averaged 30 hours paid per week during their first year, they will become eligible for medical coverage at part-time premium rates and dental and vision coverage at full cost as of the first anniversary of their hire/rehire date. Transferred Employees:   An employee who transfers to a role as a non-health benefits eligible employee will be eligible for medical, dental and vision coverage effective the first of the month following the date of transfer provided they met the average minimum paid hours’ requirement during the measurement period applicable to them and they have not met the requirements to be a retiree of the university.
When ACA Eligibility (Coverage) Ends	New Hires/Rehires—Initial Measurement Period:  Coverage will end on the one-year anniversary of the date coverage began. If coverage began in November or December, coverage will end as of December 31 following the one year anniversary of the coverage begin date.  Transferred Employees—Subsequent Annual Measurement Periods:  Coverage ends as of the end of the calendar year unless the employee met the annual measurement period for the following calendar year. In all cases, ACA coverage may be terminated earlier if the employee fails to make the required contributions to HealthEquity/WageWorks in a timely manner.