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Affordable Care Act

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On March 23, 2010, the federal government passed the Patient Protection and Affordable Care Act (PPACA). PPACA (also known as Health Care Reform or Affordable Care Act) is a set of laws designed to increase access to health insurance.

A key provision of the law, referred to as the Individual Mandate, took effect January 1, 2014 requiring all U.S. citizens to have minimum essential health coverage or else be subject to a tax penalty.

Regulations issued by the federal government require plan sponsors (including Wake Forest University) to provide notice of the Marketplace Coverage Options to all employees. The Marketplace is where individuals and smaller employers may go to purchase health insurance coverage. Open enrollment for health insurance coverage through the Marketplace begins October 1 for coverage starting January 1. While the Marketplace gives individuals more options, it is anticipated that most individuals will continue to obtain coverage through their employer. Wake Forest University will continue to offer our health plan. Please note that the Employee Only Value Plan, meets the minimum essential value and affordability requirements according to the ACA standards. For this reason, the majority of our employees will not be eligible for subsidies through the Marketplace. The “New Health Insurance Marketplace Coverage Options and Your Health Coverage” notice provides basic information about the Marketplace and about health insurance offered by Wake Forest University.

Another key provision of the law, referred to as the Employer Mandate, took effect July 1, 2015, for Wake Forest University requiring the University to:

  • Track all hours worked for all employees (faculty, staff, part-time faculty and staff, adjuncts, temporary staff, working retirees, and students)
  • Offer health care coverage to employees who work at least 30 hours per week or 130 hours per month upon hire, due to an employment status change, or due to a prior measurement period

If you have questions, you may contact Human Resources by e-mailing AskHR@nullwfu.edu or calling 336-758-4700.

The History of ACA

On March 23, 2010, the federal government passed the Patient Protection and Affordable Care Act (PPACA). PPACA (also known as Health Care Reform, Affordable Care Act, or ACA) is a set of laws designed to increase access to health insurance. Wake Forest University, along with other large employers, has been implementing the new regulations since then. Those changes have included:

  • Added medical plan coverage for dependent children to age 26
  • Cost-sharing limits for out-of-pocket costs started July 2014 and July 2015
  • Coverage for clinical trial related services
  • Coverage for women’s evidence-informed care and screenings if in-network
  • No lifetime limits on Essential Benefits
  • No pre-existing exclusions for members
  • Patient-Centered Outcomes Research Fee of $1 per member per year (ends 2019)
  • Preventive care expansion as defined by PPACA
  • Reinsurance Fee of $63 per member per year (ends 2016)
  • Office co-pays (office visits, urgent care visits, and emergency room visits) are included in the out-of-pocket maximum
  • Prescription co-pays are included in the out-of-pocket maximum
  • Offering coverage to all employees that work 30 hours per week, on average, during specific measurement periods

Individual Mandate

A key provision of this law, commonly referred to as the Individual Mandate, took effect January 1, 2014, and requires all U.S. citizens to have health insurance by January 2014 or pay a tax penalty.

Penalties:

  • 2014: 1% or$95, whichever is higher
  • 2015: 2% or $325, whichever is higher
  • 2016: 2.5% or $695, whichever is higher

Coverage available through:

  • Employer sponsored health plans
  • Government sponsored programs: Medicare, Medicaid, SHIP, and Tricare
  • Marketplace Exchange (both state and federal)

Federal government regulations require plan sponsors, including Wake Forest University, to provide a notice of the Marketplace Coverage Options to all employees. The Marketplace is where individuals and smaller employers may go to purchase health insurance coverage. Open enrollment for health insurance coverage through the Marketplace begins October 1 for coverage starting January 1.  While the Marketplace gives individuals more options, it is anticipated that most individuals will continue to obtain coverage through their employer.

Wake Forest University will continue to offer our health plan. Please note that the Employee Only Value Plan, meets the minimum essential value and affordability requirements according to ACA standards. For this reason, the majority of our employees will not be eligible for subsidies through the Marketplace. The “New Health Insurance Marketplace Coverage Options and Your Health Coverage” notice provides basic information about the Marketplace and about health insurance offered by Wake Forest University. To obtain or request a copy, you may contact Human Resources by e-mailing AskHR@nullwfu.edu or calling 336-758-4700.

Employer Mandate

Another key provision of the law, commonly referred to as the Employer Mandate, requires all large employers to offer health care coverage to employees who work at least 30 hours a week or 130 hours per month on average and is both affordable and meets minimum value requirements or pay penalties. Wake Forest’s Value Employee Only Plan is both affordable and meets minimum essential value.

Definitions:

  • Large Employer: An employer that has at least 50 full-time employees.
  • Full-time Employee: Any employee that works at least 30 hours per week, on average, throughout the year regardless of the number of jobs they have on the Reynolda Campus; this includes faculty, staff, part-time faculty and staff, adjuncts, temporary staff, working retirees, and students.
  • Affordable Coverage: Premiums for employee only medical plan coverage must not exceed 9.5% of employee’s compensation.
  • Minimum Essential Value: The Medical Plan must pay at least 60% of cost of benefits.

Requirements for the University effective July 1, 2015:

  • Track all hours worked for all employees (faculty, staff, part-time faculty and staff, adjuncts, temporary staff, working retirees, and students).
  • Offer medical coverage to any employee who averages 30 or more hours of service per week, or 130 or more hours per month either: (1) from the date of hire, as determined by Wake Forest based on the position; (2) after a change in employment status; or (3) during an applicable prior measurement period.

Penalties for Non-Compliance

For 2015, employers with 50 or more full-time employees must offer coverage to 70% of full-time employees or face potential penalties equal to the number of full-time employees minus the first 80, multiplied by $2,000.

Example: 2,600 full-time employees (faculty, staff, students, working retirees) x $2,000 = $5.2M

In 2016, this percentage increases to 95% minus the first 30 employees.

For additional information on Employer Shared Responsibility Provisions, you may visit the Internal Revenue Service (IRS) webpage.

Hours Requirement

Faculty Employment

Full-time faculty: Full-time faculty are currently eligible for medical plan coverage that offers minimum coverage and is affordable. Departments will need to provide hours for any additional work or secondary jobs.

Part-time Faculty with benefits, Part-time Faculty without benefits, and Adjuncts: In order to determine eligibility for the medical plan, credit hours must be reported for these faculty. Per ACA guidance, we will assign 3.25 hours to each credit hour assigned.  To maintain part-time/adjunct status, faculty must work no more than 30 hours per week, on average, given the credit hour equivalency. They may teach up to 8 credit hours per academic semester for all Wake Forest Colleges combined. For faculty not teaching classes, we will need hours worked for all stipends or research work and will need to pay the salary in the months in which the work is performed.

Staff Employment

Full-time exempt staff: Full-time exempt staff are currently eligible for medical plan coverage that offers minimum coverage and is affordable. Departments will need to provide hours for any additional work or secondary jobs.

Full-time non-exempt staff: Full-time non-exempt staff are currently eligible for medical plan coverage that offers minimum coverage and is affordable. All hours worked must be submitted to track regular and overtime pay. All hours worked must be recorded in NOVAtime. Add Comp payments may only be requested for bonuses, gratuities, and commissions.

Part-time Staff: All hours worked must be submitted to track regular and overtime pay as well as to determine eligibility for the medical plan.  All newly hired part-time or temporary staff should be placed on the biweekly pay cycle to track hours worked.

Temporary Employment

Wake Paid Temporary Staff: All hours worked must be submitted to track regular and overtime pay as well as to determine eligibility for the medical plan. All newly hired part-time or temporary staff should be placed on the biweekly pay cycle to track hours worked.

Non-WF paid Temporary Staff from Temp Agency or Contractor: Departments utilizing staff from a temporary agency (other than WakeTemps), need to make Human Resources aware of the agency name and temporary staff name(s).  Wake Forest University may be considered the common-law employer for employees paid by temporary staffing agencies, and may be required to track hours and offer medical plan coverage.

Student Employment

Resident Advisors (undergraduate students): Resident Advisors will be assigned 25 hours per week. This is based on a detailed calculation of their duties. Resident Advisors are not allowed to work another job on-campus without the approval from the Director of Residence Life and Housing.

Graduate Hall Directors (graduate students): Graduate Hall Directors will be assigned 20 hours per week. This is based on a detailed calculation of their duties. Graduate Hall Directors are not allowed to work another job on-campus without the approval from the Director of Residence Life and Housing.

Graduate Student Stipends: Graduate students, including Teaching Assistants, Research Assistants, Law Assistants, and Graduate School Students, will be assigned 15 hours per week. If a graduate student would like to work an additional job on campus, they need permission from their academic advisor and the Graduate School, and the total hours worked must be less than 30 per week. These hours have been established by the Graduate School.

Undergraduate and Graduate Hourly-Paid Students: All hours worked for hourly students must be submitted through Novatime to track regular and overtime pay. Undergraduate and graduate hourly student employees may hold multiple appointments, but the total hours worked for all positions across campus may not exceed 20 hours per week during the school year and 30 hours per week during official University breaks and vacations (this excludes Federal Work Study hours).

The hiring department is responsible for reviewing all jobs for a student prior to hiring them. When submitting a new job through the Electronic Personal Action Form (EPAF) process, you will be able to see if a student has another job. If you see that they have a job, please contact Human Resources so a review of potential hours in the new position can be evaluated.

Undergraduate Student Stipends: Any undergraduate student paid by a stipend, will receive the maximum number of hours worked, 30 per week or 130 per month, if actual hours worked are not submitted through a biweekly timecard in Novatime.

Working Retirees: All hours worked must be submitted to determine eligibility for the medical plan coverage. Retirees on Medicare will need to carefully decide if they wish to enroll in coverage if offered as Medicare invokes penalties for delayed enrollment in Medicare.

Hiring Manager Information

ACA Classifications

  • Full-time employee: An employee that works at least 30 hours per week, on average. This includes all faculty, staff, working retirees, adjuncts, temporary staff, and non-work study students. Beginning July 2015, Wake Forest is required to offer medical coverage to an employee that meets this definition of full-time employment. Determination will be made upon hire, during an employment status change, or after a prior measurement period.
  • Part-time employee: An employee that works less than 30 hours per week. This includes all faculty, staff, working retirees, adjuncts, temporary staff, and non-work study students. Determinations will be made upon hire, during an employment status change, or after a prior measurement period.
  • Variable/Seasonal hour employee: An employee that works varying hours and for which we are unable to determine reasonably expected hours in advance. This includes all faculty, staff, working retirees, adjuncts, temporary staff, and non-work study students. Determinations will be made upon hire, during an employment status change, or after a prior measurement period.

Tracking hours (Hours Requirement by E-Class)

ACA requires Wake Forest to track hours worked for all employees, even those that are currently eligible for benefits, in order to determine if they are considered full-time for ACA purposes (averaging at least 30 hours per week or 130 hours per month). All large employers are required by law to offer medical coverage to employees that work at least 30 hours per week or 130 hours per month:

  • Upon hire, or
  • Due to an employment status change, or
  • During an applicable prior measurement period or pay a penalty

Penalties are very significant, so we must comply with all of the ACA regulations. All large employers will also be required to file returns with the IRS and provide statements to full-time employees to document full-time status and whether or not coverage was offered.

The ACA regulations give all universities guidance on how to track adjunct and part-time faculty hours (based on credit hours), but has not provided guidance on all staff, retirees, and non-work study students. Thus, we are required to track all actual hours worked for all part-time with benefits, part-time without benefits, temporary staff, and non-work study students (graduate and undergraduate). We will also need to be mindful of breaks of service less than 26 weeks and rehires.

Per ACA, hours worked includes each hour for which an employee is paid or entitled to pay. It includes hours worked, PTO, holiday, disability, jury duty, military duty, and FMLA.

Fringe Rate

If an employee meets the ACA definition of full-time employment (30 hours per week or 130 hours per month) upon hire, due to an employment status change, or due to a prior measurement period, the University is required to offer medical coverage, and a higher fringe rate may be applied. If you have questions about fringe rates due to ACA eligibility, please contact Human Resources by e-mailing AskHR@nullwfu.edu or calling 336-758-4700.

 

Employee Information

What does it mean to be eligible for ACA medical coverage? 

  • This means an employee has met the ACA definition of full-time employment, and is eligible to elect medical plan coverage for oneself, and a spouse/same-sex domestic partner, and/or dependent children at the full-time benefit rates.

What are measurement periods? 

  • Measurement Period: A period of time that allows the University to look back at the hours worked and determine eligibility for medical coverage. For ongoing employees, this is a 12 month period, April 15 – April 14. For new hires, this is an 11 month period based on the hire date.
  • Administrative Period: A period of time that allows the University to perform administrative duties related to counting hours and offering coverage. This is usually about 4-6 weeks and will take place after April 14 each year.
  • Stability Period: A period of time, that if eligibility criteria are met, an employee is offered medical coverage. For ongoing employees, this is a 12 month period, July 1 – June 30. For a new hire, this is a 12 month period based on their hire date.

Notification Process

  • New Hire: If an employee meets the ACA definition of full-time employment (30 hours per week or 130 hours per month) upon hire, Human Resources will notify and offer healthcare coverage via email or certified mail when email access is not available.
  • Employment Change: If an employee meets the ACA definition of full-time employment (30 hours per week or 130 hours per month) due to an employment status change, Human Resources will notify and offer healthcare coverage via email or certified mail when email access is not available.
  • Measurement Period: If an employee meets the ACA definition of full-time employment (30 hours per week or 130 hours per month) during a prior measurement period, Human Resources will notify and offer healthcare coverage via certified mail.

If it is determined that an employee is eligible for ACA medical coverage, Human Resources will notify and offer healthcare coverage. The enrollment form must be completed and returned to Human Resources within 10 business days of receiving the notification, even if coverage is waived. The form may be returned by e-mail (AskHR@nullwfu.edu), mail (Wake Forest Human Resources, 1834 Wake Forest Road, Winston Salem, NC 27106), fax (336.758.6127), or campus mail.

Medical coverage is contingent upon active employment and premium payments.

Resources and Notices