Affordable Care Act (Health Care Reform)

Under the Affordable Care Act (ACA), commonly know as Health Care Reform, there are a number of requirements for employers.  Below is information for your reference.

Health Insurance Marketplace Coverage Notice

Employer Mandate

Hours Tracking for Employees Not Eligible for RIT Medical Coverage

Frequently Asked Questions (FAQ)

Frequently Asked Questions (FAQs) About Form 1095-C

 

Health Insurance Marketplace Coverage Notice

RIT is required to provide all employees with a legally required notice regarding the new “Health Care Marketplace,” previously referred to as the “Health Care Exchange.”  Under the ACA, this new Marketplace offers health insurance policies underwritten by private insurance companies.  The policies have to meet Federal guidelines for “minimum essential coverage,” which means that certain kinds of expenses must be covered.  There are several different levels of coverage available through the Marketplace.  Individuals who qualify by household income can obtain a tax credit to help make the coverage affordable.

Below are the various RIT employee types with a link to the appropriate notice.

 
Full-Time Regular
Eligible for RIT coverage
 
 
Extended Part-Time Regular
Eligible for RIT coverage
 
 
Part-Time Regular
Eligible for RIT coverage
 
 
Adjunct Employees
Eligible for RIT coverage when working
 
 
Co-op Student
Not eligible for RIT coverage
 
 
Student Worker
Not eligible for RIT coverage
 
 

 

If you have questions about the insurance products available in the Marketplace, the following resources are available:

  • www.HealthCare.gov
  • Coordinated Care Services, Inc. (585) 613-7662/V
  • Legal Assistance of Western New York (585) 325-2520/V

 

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Employer Mandate

You may have read that the “employer mandate” under ACA which was to take effect January 1, 2014, has been delayed by the Federal government. 

Beginning in 2015, employers with 50 or more employees, including RIT, are required to offer health care coverage to employees who work an average of 30 or more hours per week during the prior "measurement period" (for RIT, this is October 1, 2013 through September 30, 2014).  For employees currently in an employment category that is eligible for health care coverage, the new law has no effect on that eligibility.

At RIT we have employees in several categories of employment that are not currently eligible for coverage under RIT’s health care plans.  In order to comply with the new law, we must determine which of those employees work at least 30 hours per week, on average, during the measurement period. 

  • For non-exempt employees, including student employees, co-ops, and other non-exempt categories not currently eligible for coverage, we will use hours reported in the Kronos timekeeping system to determine eligibility.  No employee or supervisor action is needed. 
  • For adjunct faculty, we plan to use a formula that applies a ratio of work hours to credit hours taught, to determine whether an adjunct faculty member is eligible.  No employee or supervisor action is needed.
  • For other exempt employees aside from adjunct faculty, who are not currently eligible for RIT’s health care coverage, we have introduced a new process by which they need to report their weekly hours in Oracle employee self-service, beginning October 1, 2013.  We will notify impacted employees with a letter mailed to the home address in late September.

We have created this web page to help managers and employees understand the requirements and what actions, if any, need to be taken.  We will continue to add information as it becomes available.

If you still have questions after reviewing the information below, contact your benefits representative in the Human Resources Department.  Click here for contact information.

 

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Hours Tracking for Employees Not Eligible for RIT Medical Coverage

The Affordable Care Act (“ACA”), also called Health Care Reform, generally includes requirements for employers to offer medical coverage beginning in 2015, to employees who work an average of 30 hours or more per week during a 12-month “measurement period” (initially October 1, 2013 – September 30, 2014 for RIT).  (NOTE: This measurement period does not apply to employees hired after October 1, 2013; time worked for employees hired after October 1, 2013 will be measured for a 12-month period from their date of hire.)

In order to determine eligibility for RIT health care coverage beginning in 2015, we will need to know the hours worked for several categories of employees who are not currently eligible for RIT health benefits.  The categories of employees that we will be tracking include:

  1. Student Workers (including Co-op students working at RIT)
    Human Resources will be able to pull this information systematically from Kronos; therefore, no action is required for these students or their supervisors. 
  2. Adjunct Faculty
    Human Resources will use a formula based on credit hours taught for this calculation; therefore, there is no action required for adjunct faculty who teach credit-bearing courses or their managers.
  3. Other categories
    There are several other categories of employees for whom we need to know hours worked.  Examples include coaches and assistant coaches, Better Me wellness instructors, writing consultants, graduate teaching assistants, and temporary employees (on RIT’s payroll only).
    • For those who are non-exempt, we will use their hours reported in Kronos. 
    • For those who are exempt (they do not currently report hours worked), a new required process has been developed for them to complete a simple online form through Employee Self Service in Oracle each week.  The data collected will be used for RIT’s ACA compliance purposes only.  We have developed a list of Frequently Asked Questions (FAQs) [link] to provide more details about this hours worked reporting requirement.

If an employee in one of the three categories described above works on average 30 hours or more per week during the measurement period, RIT will be required to offer medical coverage to begin January 1, 2015 (based on current law). 

 

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Frequently Asked Questions (FAQs)

FAQs for Employees Who Need to Track Time Worked

 

What types of employees are required to track their time using the new weekly Oracle process?

Exempt (salaried) employees who are:

  • Not currently eligible for RIT’s health benefits, and
  • Not adjunct faculty members teaching credit-bearing courses.

Examples include coaches and assistant coaches, Better Me wellness instructors, writing consultants, graduate teaching assistants (GTAs), and temporary employees (on RIT’s payroll only).

 

Why do I need to track my hours?

RIT will be required to report to the Federal government who is and is not a “full-time employee” as defined in the Affordable Care Act (working on average 30 or more hours per week). We have no other way of determining hours worked by exempt (salaried) employees who are not currently eligible for RIT’s health benefits and not adjunct faculty members teaching credit-bearing courses.

 

What is the process to report hours for ACA?

RIT will collect the information using a simple online “form” in Oracle RIT Employee Self-Service (where you find your other employee information, including your paystubs). Please follow these steps each week beginning the Saturday ending your first week as an employee in your most recent position:

  1. Log into Oracle at http://myinfo.rit.edu (if you do not know your login information, click on Forgot Your Password or Username? link; if you have a problem, contact the ITS Service Desk at 475-5357/V and 475-2810/TTY)
  2. On the left menu, click on RIT – Hours Reporting for ACA
  3. On the menu in the middle of the screen, click on RIT - Hours Reporting for ACA
  4. Click on the Add button
  5. Enter the number of hours you worked for the week Sunday - Saturday in the box; if you are not sure, estimate to the best of your ability
    • If you didn’t work any hours in a particular week, even though you were paid (e.g., end of the term), enter 0 hours)
  6. Select the calendar week by clicking on the calendar icon, then the Saturday that is the end of the week you are reporting
  7. Click the Apply button
  8. Click the Next button to see the proposed hours reported
  9. Click the Submit button

Each week you will need to report your hours worked until you are no longer working in a position where this is required.

 

What time should I track for ACA purposes?

You should track all time spent working, including any time worked offsite.

  • If you are required to travel to an offsite workplace, you should include those hours actually worked while traveling. For example, if you do work while on an airplane you should count the time worked.
  • For those employees who drive to an offsite workplace, only the driver should include the time spent driving.
  • For travel to and from recruitment activities, include:
    • those hours actually traveled between 8 a.m. and 5 p.m.
    • any hours actually worked during this time period that were not counted as travel time, minus a one hour lunch period
    • any hours outside of this time period that are spent performing actual work.
 

What categories of graduate student employees need to track their work hours?

Graduate Teaching Assistants (GTAs) are the only category of graduate student employees who need to track their work hours. Hourly paid graduate student employees do not need to track their work hours - this includes Graduate Grading Assistants, Graduate Technical Assistants and Graduate Assistants, as well as general Student Employees. There is no need for them to track their work hours since their work hours are tracked in RIT’s time reporting system, Kronos.

Since according to the U.S. Department of Labor, no employment relationship exists between the University and Graduate Research Assistants (GRAs), GRAs do not have to track their work hours. See the Controller’s website for criteria concerning GRAs at https://www.rit.edu/fa/controller/payable/graduate.html.

 

What hours do I report if I am an adjunct also teaching a credit bearing course or I am a student working a separate job that is paid on an hourly basis?

Human Resources automatically determines hours worked for adjunct faculty members who teach credit-bearing classes using a formula based on the credit hours taught (3 hours worked weekly per each credit hour taught). For example, if a faculty member teaches a 3 credit class, this will count as 9 hours of work for the week. Human Resources obtains hourly-paid employees’ hours reported in RIT’s time reporting system, Kronos. Therefore, you only need to report your hours worked that fall outside these two categories. For example, if you are a tutor (required to track hours) and also teach a 3-hour credit course, you only need to report your hours worked as a tutor, not those worked for the 3-hour credit course. Human Resources will add your reported hours worked with our automatic calculations to obtain your total hours worked for each week.

 

Can an employee opt out of tracking if they have other medical coverage and don’t need RIT’s medical benefits?

No. RIT will be required to report to the Federal government who is and is not a “full-time employee” as defined in the Affordable Care Act (working on average 30 or more hours per week). We have no other way of determining hours worked by exempt (salaried) employees who are not currently eligible for RIT’s health benefits and not adjunct faculty members teaching credit-bearing courses. The fact that you do or do not want/need RIT’s medical benefits has no bearing on this requirement.

 

How does the Affordable Care Act affect me?

If an employee who is not currently eligible for RIT medical coverage works on average 30 or more hours per week during the measurement period (October 1, 2013 through September 30, 2014), RIT will be required to offer medical coverage to be effective January 1, 2015 (based on current law). We will provide the pertinent information in late 2014 to those who are eligible.

 

I don’t have coverage now. What can I do?

If you do not have health insurance now, you may want to check into the new coverage available through the exchange for 2014, as described in the notice we recently sent you. Under current law, if you do not have health insurance in 2014, you will have to pay a penalty to the Federal government.

 

FAQs for Supervisors of Employees Who Need to Track Time Worked

 

I am a supervisor of an employee who needs to report time for ACA purposes. Is there anything I am required to do?

Supervisors are not required to approve or input time; however, supervisors will be asked to confirm the hours for employees who indicate they worked 30 or more hours in a week.

 

What do I tell new employees who are in categories that need to track hours?

Please refer new employees to the HR website on the Health Care Reform page.  HR will contact them with the information on how and when to track their time.

 

What is the formula used to determine hours worked for Adjunct Faculty teaching credit bearing courses?

The formula is a ratio of 3 hours worked per week for every credit hour taught. This is a standard ratio in higher education. For example, if a faculty member teaches a 3 credit class, this will count as 9 hours of work for the week.

 

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