Determining ACA Eligibility

STEP 1- Determine Eligibility by looking at work hours and how long the job/assignment/contract will last.

The HR Benefits Office will monitor eligibility and compliance for the ACA for everyone that is paid by the university. In making hiring decisions, you may use the tool below for assistance in determining eligibility for ACA health coverage. (see eligibility table article for details)

STEP 2 - Understand measurement periods, look back period, stability periods and breaks in service

For all non-benefits eligible employees or temps hired on or after October 1, 2014. Our standard measurement period will be October 1, 2013 - September 30, 2014.

  • We will use a 12 month look back period to determine if the temp/employee averaged 30 or more hours per week over the prior 12 month period (measurement period). If the person averaged 30 or more hours per week, health coverage must be offered at the beginning of the 13th month.
  • If eligible and the person accepts the health coverage, it must last for at least 12 months (the stability period) regardless of hours worked (or when the employment ends). After this 12 months of coverage, if the person is working less than 30 hours per week, the coverage may be canceled.

For all non-benefits eligible employees or temps hired on or after January 1, 2015

  • If hiring for at least 30 hours or more per week AND at least for 3 months or more, health coverage must be offered within the first 30 days of hire and could begin on the first day of the month following the hire date.
  • If it cannot be determined if the position will work 30 or more hours per week OR if there is uncertainty as to the length of the assignment, the HR Benefits Office will monitor eligibility on a month to month basis.

 

Break in Service Rules

TYPE OF UNPAID BREAK IMPACT ON ACA MEASUREMENT PERIOD
Less than 4 consecutive weeks 0 hours will be factored in to the average to determine average hours for up to a 3 week maximum

4-26 consecutive week and break DOES NOT EXCEED length of pre-break employment, which includes:

  • rehired employees
  • unpaid non-FMLA leaves
  • unpaid non-USERRA (military) leave

Measurement period average will be used for each week during the break to determine average hours.

  • NOT treated as a period during which 0 hours are credited
  • NOT eligible for new measurement period

4-26 consecutive week and break EXCEEDS length of pre-break employment, which includes:

  • rehired employees
  • unpaid non-FMLA leaves
  • unpaid non-USERRA (military) leave
 New measurement period starts the first of the month following the return to work or rehire date.
More than 26 consecutive weeks New measurement period starts the first of the month following the return to work or rehire date.

STEP 3- Look at EXAMPLES to determine how a hiring decision may impact your department budget for ACA health care.    

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