Mar 28, 2014 - By Katie Roenigk, Staff WriterHuman resources officials at Central Wyoming College say they won't have to change much to comply with the employer mandate as part of the federal Patient Protection and Affordable Care Act.
The Internal Revenue Service published the final employer requirements through the ACA in February. Under those rules, beginning in January 2015 the college must provide health insurance to all full-time employees --people who work an average of 30 hours or more per week.
Jennifer Rey, CWC's executive director of human resources, said the college already complies with eligibility requirements for Wyoming's employee group insurance and retirement systems, both of which identify full-time employees as people who work 20 hours or more per week.
"Therefore, we do not anticipate a significant change in operations to comply with the PPACA employer mandate," she said.
Each employee's status will be monitored on a 12-month "look-back" basis, Rey continued. So if someone is hired part-time but ends up working more than 30 hours per week, he or she can be moved to full-time status after 12 months.
The college will offer health insurance to the employee until the next look-back period 12 months later.
Rey mentioned three ways in which ACA compliance may impact the college, beginning with student employment.
Under the final ACA rules, the only students who are exempt from the health insurance mandate are those who are employed under the federal work study program. All others are subject to the same 30-hour standard as other college employees.
Currently, student interns who are paid by the college or through grant funds are limited to working less than 20 hours per week, but Rey said they are allowed to put in more time when school is not in session.
"We will need to monitor these students to ensure compliance with the final rules," she said. "We are obligated to account for their hours worked to determine whether or not they meet that (30 hour) threshold."
In the future, she guessed that CWC may employ more students who work fewer hours.
"We'll have to look at that practice," she said. "So it'll hit us there."
Adjunct instructors are part-time employees at CWC, but Rey said they are paid based on their class load, not per hour spent on the job.
"We do not collect or track actual hours worked," Rey said. "Therefore, calculating average hours worked to comply with the employer mandate is difficult."
The PPACA addresses the issue, suggesting that employers of adjunct faculty use a "reasonable method" for crediting hours of service for those employees, who often spend time preparing for class or correcting student work outside of school.
One tactic would be to credit an adjunct faculty member with 2.25 hours of service for each hour of teaching or classroom time, Rey said. Another idea is to consider the hours that adjunct employees work outside of the classroom hosting office hours or attending meetings, for example.
Rey expects that changes to CWC's adjunct policy will be in place by July of this year. Currently, she said adjunct professors are limited to nine "load hours" per semester, but exceptions are often permitted.
"We tend to have a pool of adjuncts we're comfortable working with, (and) we use them recurringly," Rey said. "We may have to expand our adjunct pool to add more adjuncts teaching different sections in order to meet the standards."
A handful of CWC employees work for at the college in a variety of part-time, non-benefitted positions, as tutors, adjunct instructors and community educators, Rey said. To comply with the ACA employer mandate she will have to combine all of the hours each individual works in order to accurately assess whether the employee exceeds the ACA's 30-hour, full-time threshold. The calculation will be based on the 12-month look-back measurement period established for all workers.
"(We are) currently evaluating how best to address the dual/multiple employment issue," Rey said.
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