The Affordable Care Act (ACA) is a comprehensive federal health care reform law with provisions that are being phased in over a period of several years. The legislation seeks to ensure quality of coverage and guarantee access and affordability.

WHAT DO EMPLOYEES NEED TO KNOW?

For benefits-eligible UVM employees, there will be no changes during the 2016 calendar year to the medical insurance plan offered by UVM. The university's existing benefits meet the ACA's requirements for affordability, benefit value and coverage.

WHAT MUST AN EMPLOYEE DO TO COMPLY WITH THE ACA?

  • The ACA required most Americans to have medical insurance by January 1, 2014, or pay an income tax penalty. The law offers individuals the ability to choose how and where to get coverage.  
  • If individuals already have medical insurance through an employer-sponsored plan (such as the UVM medical insurance plan), Medicaid, Medicare, or private insurance, they can keep it.  
  • Individuals may choose to purchase medical insurance from Vermont Health Connect (the Vermont "healthcare exchange") and possibly qualify for a federal subsidy.

WHAT MUST THE UNIVERSITY DO TO COMPLY WITH THE ACA?

UVM's current employee medical plans are qualified in the Vermont marketplace as a result of providing essential health benefits, following established limits on cost-sharing, and meeting ACA requirements.

  • Effective January 1, 2015, large employers like UVM (50 or more employees) will incur penalties if they fail to offer health insurance benefits to all employees who average 30 or more work hours per week, or 130 hours per month, for a 12-month period.
  • To ensure that all UVM employees who average 30 hours of work per week are offered medical insurance, UVM departments are assisting Human Resource Services in accounting for hours worked by historically non-benefits-eligible employees.
  • Variable Hour Employees
  • Temporary Faculty and Staff

All temporary employees who work an average of 30 hours or more per week (130 hours per month) during the 12-month measurement period (October 15, 2014 through October 15, 2015) will be offered UVM-sponsored medical insurance for the 12-month stability period that begins January 1, 2016. Insurance will be offered to employees, who may also choose to cover their eligible dependent children. Spousal coverage will not be provided. Coverage will continue for the entire twelve month stability period, regardless of hours worked, for qualified employees who enroll in the UVM plan following the offer of insurance. If these employees enroll in the UVM plan and then leave the University during the stability period, they will be eligible for continued coverage under COBRA provisions.

NON-BENEFITS-ELIGIBLE FACULTY

There are a variety of academic positions within the University in which faculty are assigned variable hours. UVM has established guidelines based on course load for non-tenure track faculty whose primary duties are teaching courses. For faculty not assigned a full-time equivalent (FTE), the ACA permits assignment of 3.33 hours per week for each credit taught, to cover classroom time, student advising and related work. After calculating teaching hours in this way, UVM will assign an additional one hour per week for department or other University business, such as faculty meetings.

Non-teaching work assigned to part-time faculty working variable hours will be recorded on the basis of the actual hours specified in their individual compensation agreements.

UNDERGRADUATE STUDENT EMPLOYEES

Students use part-time jobs both to offset their educational expenses and to gain work experience. Student employees must be enrolled at UVM with a minimum enrollment of one credit hour. The majority of student workers do not exceed 20 hours per week in order to focus on their academic programs. Students who work a combined average of 30 hours or more per week in all non-Work Study jobs over a 12-month measurement period must be offered access to the employer medical plan, although they may decline or waive the coverage in favor of their student health insurance or other private insurance.

Departments are expected to monitor student hours to ensure compliance with requirements of the Student Employment Office.

GRADUATE ASSISTANTS / PRE AND POST-DOCTORAL ASSOCIATES

When a graduate assistant (GA) or Pre-Doctoral or Post-Doctoral Associate receives W-2 wages, their hours of service will be counted in order to determine whether they are a full-time employee for ACA purposes. Under requirements of the Graduate College, GAs at .50 FTE or less may pursue additional supplemental compensation up to a maximum of 30 hours per week. To facilitate tracking GA supplemental compensation, home hiring units will be asked to clearly state work hour commitments on any supplemental compensation forms (additional pay forms).

POST-DOCTORAL FELLOWS AND TRAINEES

Postdoctoral Fellows/Trainees are not considered to be University employees. Postdoctoral Fellows are currently eligible for University medical insurance coverage under terms and conditions described by the Graduate College.

BREAKS IN SERVICE DUE TO THE ACADEMIC YEAR

UVM will apply the ACA's special rules for educational institutions in order to prevent averaging employee hours of service over a 12-month period in a way that could distort measurement by including summer months or other periods when employees have no assigned work hours.

 

Departments

WHAT DOES MY DEPARTMENT NEED TO KNOW ABOUT THE ACA REQUIREMENTS?

Effective January 1, 2015, the ACA requires UVM and other large employers to offer medical insurance benefits to any employee averaging 30 work hours or more per week (130 hours per month). This requirement is referred to as the "employer mandate" of the ACA. The 12-month "measurement period" that will be used to determine employee eligibility for UVM medical insurance benefits is October 15, 2014 through October 15, 2015 (see below).

FOR BENEFITS-ELIGIBLE UVM EMPLOYEES

The University currently offers a comprehensive medical insurance plan to employees who work 50% or more for 9, 10, 11, or 12 months (academic year). Approximately 3,800 UVM employees are benefits-eligible in this way.

The ACA does not require that these individuals make any changes to their medical benefits, nor will these employees see any changes to their medical benefits as a result of the ACA's employer mandate taking effect on January 1, 2015.

FOR NON-BENEFITS-ELIGIBLE UVM EMPLOYEES

Non-benefits-eligible employees include those employees who do not regularly work, on average, 30 hours or more per week. ACA guidelines describe these employees as "variable hour" employees. At UVM, variable hour employees include:

  • Temporary Faculty and Staff Employees
  • Student Employees (non-Work Study)
  • Graduate Assistants
  • Pre-and Post-Doctoral Associates
  • Part-time Lecturers and other part-time or adjunct faculty

To ensure compliance with ACA requirements to monitor and report the hours worked by variable hour employees, departments will be asked to assist in creating accurate employment records for all such individuals.

HOW WILL UVM DETERMINE ELIGIBILITY FOR MEDICAL INSURANCE FOR VARIABLE HOUR EMPLOYEES?

The ACA provides the following method to determine if a variable hour employee has reached the 30-hour-per-week threshold and should be offered medical insurance:

For ACTIVE Variable Hour Employees (employed as of October 15, 2014)
UVM will "look back" at a 12-month measurement period to determine whether an individual employee AVERAGED 30 hours of work per week (130 hours per month).

The current measurement period began on October 15, 2014.

If employees work an average of 30 hours or more per week (130 hours per month) during the measurement period, they must be offered UVM-sponsored medical insurance for a period of time in the future, called the stability period. If the qualified employee enrolls following the offer of insurance, coverage will continue, regardless of hours worked, for the entire stability period. If they leave the University during the stability period, they are eligible for continued coverage under COBRA provisions.

  • The Stability Period will be January 1 through December 31 each year.
  • The first Stability Period will begin on January 1, 2015.
  • There is an administrative period between the measurement and stability periods. During this time, employees will be notified that they are eligible for UVM medical insurance and eligible employees will be able to enroll for coverage that will begin on January 1.
  • The administrative period will be October 15 through December 31 each year.
  • The first administrative period will begin on October 15, 2014.
  • For NEW Variable Hour Employees (hired after October 1, 2014)

Each employee will have an individual measurement period of 11 months that will begin on the first of the month following the date of hire. On the following October 15, the new employee will be included in a measurement period for existing employees, as described above.

FAQs

WHAT IS CHANGING?

Included in the Affordable Care Act is a mandate for UVM to offer medical coverage to employees who AVERAGE 30 hours per week (130 hours per month) or more across all UVM jobs over a defined measurement period. The university's measurement period is 12 months (October to October, each year).

ARE THERE ANY CHANGES FOR EMPLOYEES WHO ARE ALREADY FULLY BENEFIT ELIGIBLE ?

No. There are no changes for employees who are already benefit eligible. The information below applies to variable hour employees who do not currently receive health insurance coverage.

AM I REQUIRED TO HAVE HEALTH INSURANCE UNDER THE ACA?

Beginning on March 31, 2014, individuals without health insurance may be subject to an IRS fine.

WILL THE HEALTH INSURANCE COVERAGE OFFERED BY UVM CHANGE IN 2015-16?

No, existing health insurance coverage will continue to be offered, unchanged and uninterrupted.

WHAT IS THE HEALTH INSURANCE MARKETPLACE?

The Health Insurance Marketplace, sometimes known as the health insurance "exchange," was launched on October 1, 2013, as part of the ACA. It is a new way for Americans to purchase health insurance. More information on the Health Insurance Marketplace can be found at www.healthcare.gov. Vermonters who fit the eligibility criteria, including some UVM faculty, staff and temporary e mployees, may purchase healthcare coverage through Vermont Health Connect (VHC, also called "the Exchange" or "the Marketplace").  See the VHC website for details.

WHEN DOES THE HEALTH INSURANCE MARKETPLACE OPEN?

The next open enrollment period on the Health Insurance Marketplace is November 10, 2015, through December 4, 2015, and coverage starts January 1, 2016. If you have a qualifying life event, you may be eligible to enroll outside the open enrollment period. More information on the Health Insurance Marketplace can be found at www.healthcare.gov.  Information on the Vermont Health Exchange will be found on the VHC website.

WHAT IS THE MARKETPLACE COVERAGE OPTIONS NOTICE?

The notice is intended to provide UVM employees with some basic information about the VT Health Insurance Marketplace and their health insurance options. ACA regulations require UVM to provide this notice to all existing employees. This notice was distributed to for the first time to UVM employees in October  2013. It has also been made available to all new employees hired on and after October 1, 2013. New employees receive the notice in their new hire packet.

IS THE HEALTH INSURANCE MARKETPLACE MY ONLY OPTION FOR HEALTH INSURANCE?

No. Health insurance benefits will continue to be available to eligible employees through UVM and the VT Health Care Exchange.  Other options include Medicare, Medicaid, and private insurance. Non-benefits-eligible employees who enroll in coverage through the Marketplace may be eligible for subsidies. More information is available at the VHC website.

WHAT IS A MEASUREMENT PERIOD?

The term measurement period indicates a time frame for the employer to "look back" to determine if an employee met the 30-hour per week or 130 hours per month eligibility requirement. The next measurement period for UVM will be October 15, 2014 to October 15, 2015. Employees who AVERAGE 30 hours or more per week (130 hours per month) over this 12-month period will be offered medical coverage for the benefit year beginning January 1, 2016. This process will repeat each year.

WHAT DOES THE TERM VARIABLE HOUR EMPLOYEE MEAN?

A variable hour employee has been referred to as "part-time" or "temporary" in the past but this language has changed for ACA purposes. A variable hour employee is one who works for the University but is not fully benefit eligible at the time of hire.

WHO WILL BE REQUIRED TO TRACK WORK HOURS AND HOW/WHERE WILL THEY TRACK TIME?

  • Hourly employees enter their time weekly in the payroll system.
  • All non-teaching exempt employees and faculty with teaching academic appointments will not track hours.  Instead, the FTE recorded in the PeopleSoft system, based on their appointment letter will be used.
  • Teaching faculty and graduate teaching assistants with no FTE will be assigned hours based on an equivalency of 3.33 hours for each credit hour assigned, plus one additional hour per week for department business.

HOW ARE HOURS WORKED CALCULATED FOR PEOPLE WITH A COMBINATION OF TEACHING AND ANOTHER TYPE OF ACTIVITY?

When a variable hour employee has more than one type of work or more than one assignment, separate job records are maintained for each concurrent job. This allows for each job to be tracked separately using the applicable approach (see above). The hours will be combined to determine if the individual is eligible to be offered health insurance coverage under ACA.

HOW DO BREAKS IN SERVICE IMPACT THE MEASUREMENT PERIOD?


The regulations state that breaks in service greater than 26 weeks require employees to begin a new measurement period (individual). If the break in service is not expected to last longer than 26 weeks, the individual will be placed on leave, as appropriate. When an employee has a break in service of less than 26 weeks, they will be placed back into the same measurement/coverage period that they were in at the time of their break began. Any breaks in which there are no hours worked in a four week period are excluded from the calculation. If there are any hours worked during a summer month, then that month will be included in the calculation.