Under the Affordable Care Act (ACA), non-benefits eligible employees may become eligible for the University’s health plan for a calendar year if they work an average minimum paid hours of 30 per week during a look-back measurement period.
A look-back measurement period is established annually to determine eligibility for medical coverage at part-time health premiums for the following calendar year. This annual measurement period begins on each October 3 and ends on October 2 of the following year. Employees who are eligible due to meeting the requirements for ACA coverage are only eligible for medical coverage.
New hires
Employees who are hired into a non-benefits eligible role will have an initial lookback measurement period that starts as of their hire date and ends 12 months later. Subsequent measurement periods begin on each October 3 after the date of hire through October 2 of the following year. A newly hired non-benefits eligible employee who meets the minimum paid hours required during their initial measurement period will be eligible for health coverage at part-time rates as of the date the initial measurement period ended.
Two examples:
- A non-benefits eligible employee hired on April 19, 2021, will have an initial measurement period that begins on April 19, 2021, and ends on April 18, 2022. If the employee works an average minimum paid hours of 30 per week during this initial measurement period, they will be eligible to enroll in one of the University’s health plan options at the part-time premium rates effective April 19, 2022, for the remainder of the 2022 calendar year through April 18, 2023. If the employee also met the average minimum paid hours during the annual lookback measurement period that started on October 3, 2021 and ended on October 2, 2022, their coverage will continue through the end of 2023 provided they remain employed by the University and make the required contributions in a timely manner. If they did not meet the annual minimum hours paid during the annual lookback period, their health coverage will end on April 30, 2023. In either case, to be eligible for the 2024 calendar year, the employee would have to meet the average minimum paid hours’ requirement for the measurement period starting October 3, 2022 through October 2, 2023.
- A non-benefits eligible employee hired on November 15, 2021, will have an initial lookback measurement period that begins on November 15, 2021, and ends on November 14, 2022. If the employee works an average minimum paid hours of 30 per week during this initial measurement period, they will be eligible to enroll in one of the University’s health plan options at the part-time premium rates effective November 15, 2022, for the remainder of the 2022 calendar year through December 31, 2023, provided they remain employed by the University and make the required contributions in a timely manner. To be eligible for the 2024 calendar year, they would have to meet the average minimum paid hours’ requirement for the measurement period starting October 3, 2022 through October 2, 2023.
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). Employees who are eligible due to meeting the requirements for ACA coverage are only eligible for medical coverage.
Transfers to a non-benefits eligible role
A benefits eligible employee who transfers to a non-benefits eligible role and who met the average minimum paid hours requirement during the annual or initial measurement period applicable to them will be eligible to continue medical coverage at part-time rates for the remainder of that calendar year provided they remain employed by the University and make the required contributions 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 non-benefits eligible role.
For the following calendar year, the employee will be eligible for medical coverage if they meet the average minimum paid hours’ requirement during the annual measurement period that ends after the date of transfer.
Two examples:
- A full-time benefits eligible employee who was hired in 2015 transfers to a non-benefits eligible role on July 15, 2021. Since the employee met the average minimum paid hours requirement during the annual measurement period that ended on October 2, 2020, the employee will be eligible to continue medical and vision coverage at part-time premium rates for the remainder of 2021. Within 31 days following the date of transfer, the employee may elect to retain their current medical option, change to a different medical option or drop coverage. The employee’s other active health and insurance coverage will end on July 31, 2021, and they may be eligible to elect COBRA for some benefits.
For the 2022 calendar year, the transferred employee has a measurement period that began on October 3, 2020, and ends on October 2, 2021. If the employee works an average minimum paid hours of 30 per week during this measurement period, they will be eligible to enroll in one of the University’s health (medical) plan options at the part-time premium rates for the 2022 calendar year provided they remain employed by the University and make the required contributions in a timely manner. Note that for 2022, the transferred employee will not be eligible for either basic vision or the vision buy-up option.
- A part-time benefits eligible employee who was hired in 2018 and whose standard work schedule is 20 hours per week transfers to a non-benefits eligible role on August 15, 2021. In this case, the employee did not meet the minimum paid hours’ requirement for ACA coverage during the annual measurement period that ended on October 2, 2020. As a result, the employee’s active health and insurance coverage will end on August 31, 2021, and they may be eligible to elect COBRA for some benefits.
As in the example above, to be eligible for ACA health coverage in 2022, the transferred employee must meet the average minimum paid hours of 30 per week during the annual measurement period that began on October 3, 2020 and ends on October 2, 2021.
The following chart summarizes how the University determines ACA eligibility:
| Population Measured for ACA Eligibility | Only non-benefits eligible employees (scheduled hours less than 20 hours per week), including adjuncts; Measurement begins when they are hired into ineligible status. If an employee transfers to a non-benefits eligible status, 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 that a variable hour employee’s weekly average hours are measured. Both the standard and initial measurement periods are on a 12-month “look back” measurement method to determine the weekly average hours paid for variable hour employees. |
| Stability Period |
Calendar year. If an employee meets the average hours paid requirement during the standard measurement period, they become eligible for health care coverage at part-time rates 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 non-benefits eligible role to one-year anniversary. 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: If they have averaged 30 hours paid per week during their first year, they will become eligible for health care coverage at part-time premium rates as of the first anniversary of their hire date. Transferred Employees: An employee who transfers to a non-benefits eligible role will be eligible for health care coverage at part-time premium rates 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. |