Certain part-time employees at Ohio Wesleyan can receive health care benefits as designated by the Affordable Care Act. Designated employees averaging 30 or more hours of work per week (or equivalent) are eligible for employee health care benefits.
AFFORDABLE CARE ACT: PART-TIME EMPLOYEES AND HEALTH CARE BENEFITS
For OWU students, adjunct faculty, and other employees, 30 hours a week is the new "full time" under the Affordable Care Act. Working 30 hours or more a week entitles an employee to be offered health care benefits beginning Jan. 1, 2015. Read more in this IRS Affordable Care Act Q&A.
DETERMINING EMPLOYEE STATUS
Since 2010, determining who counts as an employee under the Affordable Care Act has been, and remains, a "crystal ball" exercise with little consistency or clarity from the federal government. The links below can help with employee definition as well as with information on the ACA’s impact on adjunct faculty and student workers. OWU’s HR Office is ready to answer specific questions, too.
One “reasonable method” to calculate adjunct work is to say that for every hour spent teaching, instructors work an additional hour and 15 minutes outside the classroom grading papers and preparing for class. Required duties for adjuncts outside of the classroom, such as faculty meetings or office hours, may be credited as an hour of service per week for each hour spent on tasks. The guidance notes that “employers may credit more hours of service than would result under the method described and may offer coverage to additional employees beyond those identified as full-time employees under that method.”
Institutions may use other “reasonable methods” for crediting hours of service for adjunct faculty, given the "wide variation of work patterns, duties, and circumstances" at different colleges. While the administration may consider further guidance on this issue, institutions can rely on this formula for calculating adjunct hours at least through the end of 2015.
Service performed by students in positions subsidized through the federal Work-Study Program (or a similar state or other program) do not count as hours of service for ACA purposes. The exemption is limited to these programs, however, and “[a]ll other hours of service for which a student employee … is paid … are required to be counted as hours of service.”
The guidance does not provide an exemption for graduate students functioning as research or teaching assistants, so institutions must carefully manage working hours to determine whether the assistantships qualify as full-time in accordance with the ACA. With respect to internships and externships, the guidance states that services by an intern or extern would not count as hours “to the extent that the student does not receive, and is not entitled to, payment in connection with those hours.”
However, some paid interns or externs, particularly during a semester as well as the summer, may qualify for exemption as seasonal employees. The guidance has a full section detailing how to determine whether an employee qualifies as seasonal. In addition, the potential application of the employer mandate to internships or externships will be delayed until 2016 for students working at mid-size firms (50 to 99 employees) and phased in during 2015 for larger employers (100 or more employees), so there will be time to fully assess the effect of this guidance.