1. Affordable Care Act (ACA) Overview
Wilkes County Schools

2. Background
Effective January 1, 2015 “applicable large employers” (ALEs) with 100 or more full-time equivalent employees must offer an insurance package that meets minimal ACA requirements at the “bronze level”.
The State Health Plan has created a plan entitled the “High Deductible Health Plan” to meet these requirements. The plan will be run by CobraGuard.

3. Qualification
Currently the Public Schools of North Carolina have certain requirements that employees must meet in order to be benefit eligible. Typically interim and temporary employees are not eligible for health insurance benefits through the State Health Plan.
The ACA is designed to offer insurance to employees that average 30 hours or more per week that do not already receive insurance coverage. For Wilkes County Schools, this means interim/temporary employees such as classroom subs, SFS subs, interim teachers, and other interim/temporary employees.

4. How is eligibility determined?
For an employee to be eligible they must average 30 hours per week. The method for determining if an individual qualifies is based on the category of employee.
Variable: it cannot be determined at the hire date that the employee will average 30 hrs. per week.
Non-variable: The employee is reasonable expected to average 30 hrs. per week at the initial hire date regardless of the length of employment.
Seasonal: 6 months or less, hired at the same time each year.

5. Non-variable Employees
If an employee is reasonably expected to work 30 hours or more when hired, they are considered non-variable.
Prior to Oct.1,2014
WCS used a safe harbor look back period of Oct. 1, 2013 – Sept. 30, Any employee that was a non-variable employee during this time that is still and are currently employed, they will be offered the HDHP insurance during the month of December.
October 1, 2014 and beyond
The HDHP will be offered to all interim/temporary employees that will be reasonably expected to work 30 hours when hired. It will take effect the first day of the month following the hire date.
Action forms will be review and data will be maintained in Human Resources to identify these employees.
Employees that are offered the insurance do not have to accept the insurance, but must meet with Human Resources to document the offering.

6. Variable Employees
It cannot be determined at the hire date that the employee will average 30 hrs. per week.
Prior to Oct. 1, 2014:
WCS used a safe harbor look back period of Oct. 1, 2013 – Sept. 30, If an employee averaged 30 hrs. per week during this time and are currently employed they will be offered the HDHP insurance during the month of December.
To average 30 hours per week, an employee had to work 75% of the available work days. For example a substitute teacher had to work days.
If a variable employee qualifies and accepts the insurance they are eligible for the insurance for up to a year after being offered, regardless of the hours worked. The employee will be reassessed at the end of the annual look back period ending September 30th.

7. Variable Employees October 1st and beyond:
When a new variable employee is hired, they will have an annual measurement period of one year that begins on the first day of the month following their hire date. If the employee averages 30 hours per week during this initial measurement period, they will be offered the HDHP if still employed by WCS. Those eligible can keep the insurance for the following stability period of 1 year and then will be reassessed.

8. Seasonal Employees
Seasonal employees will follow the same guidelines as “variable employees”.

9. Break in Service
Includes termination/rehire, layoff/recall, ending temporary/interim employment and rehire.
Any employee that has a break in service (no hours of service) for 26 weeks or longer is treated as new employee.
Any employee that has a break in service of less than 26 weeks, will maintain their previous status and measurement period when rehired.
An employee is also considered to have a break in service if the employee has no hours of service for 4 weeks longer than originally employed. If rehired, they are treated as a new employee.

10. Special Leaves
If an employee takes a special leave (FMLA leave, USERRA leave, or jury duty) those days must be counted as “worked days” or the days have to be subtracted from the look back period.

11. Employment breaks
Employment breaks are treated in the same manner as special leaves. Employment breaks are defined as a period of at least 4 consecutive weeks during which an employee of an educational organization is not credited with hours of service. An example would be summer break. No more than hours are required to be excluded or credited.

12. Impact on retirees
Recent legislation passed by the General Assembly states that if a rehired retiree meets the eligibility requirements of the HDHP, the employer must offer the retiree coverage in the HDHP.
The retiree is not required to enroll in the HDHP but the retiree is no longer eligible for the state health plan retiree insurance.
WCS will be required to notify the state of eligibility and their insurance plan will be terminated.

13. Retiree Re-enrollment
HDHP eligibility for retirees does not become effective until Jan. 1, 2015, however qualification is being determined now and from this point forward.
If a retiree is eligible for the HDHP and ends employment with WCS the employee will be offered Cobra insurance. The retiree will have 30 days to re-enroll in the state health plan coverage under the retirement system.
If they do not re-enroll within 30 days, the will be unable to come back on the plan until the next enrollment period.

14. A quick look at the HDHP
Monthly Contributions: Employer = $117.62, Employee = $92.38
6 Benefit Design Individual Coverage Family Coverage
Deductible $5, $10,000
Out-of-Pocket Max. $6, $12,900
Coinsurance 50% %
ACA Preventive Medical Covered at 100% in-network
ACA Preventive Pharmacy Covered at 100% in-network

15. Options for retirees
Reduce work schedule to a max of 29 hours prior to Dec. 31st
If a retiree qualifies they must have a break in service for 26 weeks or 4 weeks longer than employed.
Resign immediately and return after 26 weeks
Come our of retirement if an option
Retirees will have to closely monitor their time from this point forward.

16. How does this effect WCS?
Tutors will remain at less than 20 hours.
We will have to closely watch the combination of job ex.Drivers Ed teachers and Substitute teaching.
We will not limit substituting to 3.5 days per week at this time.
Those hired at 30 hours a week (interim/temporary) will be offered the ACA when hired.
Retirees will have to monitor their work time when performing variable jobs such as substituting.
Retirees will no longer be able to fulfill leaves as a 30 hr. week teacher, but only as a sub.

17. Questions??