1

Update on the Affordable Care Act

Council of DeansOctober 28, 2014

2

Planning Assumptions

• Penn to comply with law.

• New ACA eligibility begins July 2015.

• University-wide collaborative effort. Provost, H.R., ISC, Budget, Finance, OGC, Schools and Centers.

• Penn will offer medical coverage to part time academic support staff, administrative staff and temporary workers who achieve full time equivalency (i.e., average of 30+ hours per week).

• Penn will charge the full time employee benefit rate to part time faculty, staff and temporary workers who achieve ACA full time equivalency (30+ hrs. week), whether or not they elect to enroll

.

3

Full Time Equivalency For ACA

• For all current faculty and staff and future hires, Penn must determine whether expected work equal 30+ hours per week.

• This determination can be based on monthly measurement or “look-back” methods. (Penn is a research institution that operates all year; our look back eligibility determination period began July 1 2014.)

• Methods include: • Count Actual hours worked for non-exempt staff based on payroll

records• Exception time reporting for part time monthly paid staff• For faculty, 30+ hours =

• 3 courses in the Fall and 3 courses in the Spring • 9 semester hours in academic year • 2.5 CUs in academic year • 3.75 per diem days

4

Part Time Faculty

• Require institutionalized use of template letters of appointment that include expected work hours. Required for ALL hires.

• Developed equivalency matrices based on number of courses taught, semester hours taught, course units taught and per diem service to aid schools in determining faculty member’s expected work hours equal 30+

• Working with Schools to review Hours field in PennWorks

• To help control costs and improve data integrity will implement “Auto-termination” for part time faculty not paid in 4 months with no active appointment.

(If there is a reasonable expectation that the part time faculty member will teach the following Fall/Spring semester, the role end date can be updated in PennWorks by the schools and the individual will not be auto-terminated)

5

Part Time Staff

• Any Temp who works an average of 30+ hours in any 90 day period must be offered medical coverage. Full time employee benefit rate will be charged.

• Penn will continue to monitor Temps who work > 1,000 hours in a fiscal year. Departments will be charged at the full time employee benefit rate

• Penn will NOT limit temporary workers hours or role duration

• Expand use of Pilot Position Information Questionnaire for Temps

• Alternative: Expand use of third party agency for temporary staff

6

Work in Progress

Benefits Design under ACAMedical Coverage only

- Must be affordable - Must provide essential minimum benefits

Ambulatory patient services; Emergency services, Hospitalization; Maternity and newborn care; Mental health and substance use disorder services; Prescription drugs; Laboratory services; Rehabilitative and habilitative services and devices; Preventive and wellness services and chronic disease management; Pediatric services

No change at this time to current offering for PT employees where the colleague has access to medical plans but pays 100% of the cost.

Auto-enrollmentEstablish an administrative period to review eligibility determinationProcess if employee does not respond during enrollment periodRolling enrollments as new part time hires achieve eligibility.

Reporting (January 2016)ACA requires dual reportingInternal Revenue Service and Employee (must include dependent information)

7

Sample of ACA Reports – Form 1095-C