“Creating A More Educated Georgia”

The Affordable Care Act (ACA)Shared Responsibility Mandate

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“Creating A More Educated Georgia”

Shared Responsibility Mandate

If employer offers coverage, must be offered to 95% of full-time employees

Must be Affordable Must meet Minimum Value Standards Use Safe Harbor guidelines to determine track time of

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Coverage

Defined as: 95% of full-time employees Full-time is defined as average of 30+ hours per week Includes employee’s children to age 26 Spouses or domestic partners not required Must have the opportunity to enroll at least once per year

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Affordability

Affordable coverage is coverage that is 9.5% or less of household income

Federal government offered 3- Safe Harbors to employers USG is using the Federal Poverty Line Safe Harbor: Must

offer coverage with an employee premium that is 9.5% or below the Federal Poverty level 2014 Federal Poverty level is $11,680; 9.5% of $11,680 is $1,110 or a monthly premium of $92 USG High Deductible Health Plan monthly premium is $47

Under Safe Harbor, employee is not eligible for subsidy in the exchange market and USG would not be subject to penalties

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“Creating A More Educated Georgia”

Minimum Value

60% minimum plan value based on ACA rules definition of “essential health benefits”

Healthcare Plan’s actuary has confirmed all USG Healthcare plans meet Minimum Value coverage as defined by ACA

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Penalties for not meeting Shared Responsibility requirements

If don’t meet coverage requirements: $2,000 times total number of FTEs – not counting first 30 FTEs if

don’t meet coverage requirements If don’t meet affordability requirements:

Up to $3,000 annually for each FTE receiving income based assistance for health insurance exchange coverage

Each USG institution’s management is accountable and responsible for achieving and maintaining compliance with the requirements under the Affordable Care Act

Each USG institution will be held financial accountable for non-compliance

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Tracking Time Worked- initially all employees not offered health insurance

Safe Harbor Tracking Method Look-back or measurement period (3-12 months), this is the period of

time in which hours will be tracked for part-time employees; standard year after year

After the measurement period, employers have the option to have an administrative period (up to 90 days); this period is used to determine eligibility and facilitate enrollment of any employees who meet eligibility

Stability period – period during which part-time employees who met eligibility may elect to participate in the healthcare plan (6-12 months)

Hours worked for faculty must be calculated based on the academic year to determine eligibility unless they work during the summer

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Example Tracking Periods

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Reporting

Employers are required to report their employer provided health coverage data to the Federal Government

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Three Major Impacts1. Must revise the USG Employee Category Policy and the

definitions of employment and employee types2. Develop a Conversion Chart for Credit hours to hours worked for

part-time faculty3. Set up tracking method to determine health benefits eligibility for

part-time workers

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“Creating A More Educated Georgia”

Final Guidance Released February 10, 2014

Further Guidance on types of employees and hours of service

2015 Transition Tracking Period Provisions Transitional 6 month tracking period Must begin

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Definitions from Guidance Seasonal Variable Hour Adjunct Faculty Rehired employees

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Student Employees

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“Creating A More Educated Georgia”

Proposed Definition of Student Employees

Currently not exempt under ACA Proposed solution is to revise the Employee Category Policy:

Students must work part-time except during the summer and holidays and may not exceed 1300 hours in any consecutive 12-month period

International students and work study students must work no more than 20 hours per week

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“Creating A More Educated Georgia”

Next Steps

Collect feedback from this group and from system-wide VPAAs, CBOs, and CHROs, last week of February or first week of March

Finalize documents and distribute system wide mid-March Training sessions first two weeks in April

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Send suggestions/comments to VPAA listserv

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