“Creating A More Educated Georgia” The Affordable Care Act (ACA) Shared Responsibility Mandate 1.

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Presentation transcript:

“Creating A More Educated Georgia” The Affordable Care Act (ACA) Shared Responsibility Mandate 1

“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 2

“Creating A More Educated Georgia” 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 3

“Creating A More Educated Georgia” 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 4

“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 5

“Creating A More Educated Georgia” 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 6

“Creating A More Educated Georgia” 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 7

“Creating A More Educated Georgia” Example Tracking Periods 8

“Creating A More Educated Georgia” Reporting  Employers are required to report their employer provided health coverage data to the Federal Government 9

“Creating A More Educated Georgia” Three Major Impacts 1.Must revise the USG Employee Category Policy and the definitions of employment and employee types 2.Develop a Conversion Chart for Credit hours to hours worked for part-time faculty 3.Set up tracking method to determine health benefits eligibility for part-time workers 10

“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 11

“Creating A More Educated Georgia” Definitions from Guidance  Seasonal  Variable Hour  Adjunct Faculty  Rehired employees 12

“Creating A More Educated Georgia” Student Employees 13

“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 14

“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 15

“Creating A More Educated Georgia” Send suggestions/comments to VPAA listserv 16