Affordable Care Act

Introduction

The Affordable Care Act (ACA) requires employers that have 50 or more full-time employees to offer medical insurance to full-time employees and their children up to age 26. Coconino Community College offers a comprehensive package to its benefit-eligible employees that meets the federal ACA requirements.

The following FAQs have been developed to assist in administrating the ACA. 

Please contact the Compliance Specialist at (928) 226-4252 with inquiries. Questions regarding employment definitions should be sent to This email address is being protected from spambots. You need JavaScript enabled to view it..

Key Concepts

Employer Shared-Responsibility or “Pay or Play” Mandate

Employers with at least 50 full-time equivalent employees (full-time considered at 30 hours) are required to offer affordable, minimum value health insurance to their full-time employees or be subject to potential tax penalties under section 4980H if an eligible employee enrolls through the exchange and qualifies for a subsidized premium.

Individual Mandate                 

The Affordable Care Act requires nearly everyone to have health insurance that meets minimum standards.  With some exceptions, people who do not maintain health insurance coverage will have to pay a penalty as of 2014. 

Key Terms

Full-time Employee

Under the ACA, an employee working 30 or more hours a week is considered full-time.  A new employee who is reasonably expected to work full-time (an average of 30 hours per week) at his or her start date for 90 days or more is considered benefits eligible base on ACA rules.

Variable Hour Employee

A new employee is considered a variable hour employee, if based on the facts and circumstances at the start date, it cannot be determined that the employee is reasonably expected to work on average at least 30 hours per week for 90 days.

Measurement Period

The Measurement Period or “look-back period” is a safe harbor method to provide employers the option to use a look-back measurement period of up to 12 consecutive calendar months to determine whether variable hour employees or seasonal employees are full-time employees, without being subject to a payment under 4980H for this period with respect to those employees.

Stability Period

The period of time a “variable hour” employee that averaged 30 hours during the measurement period would be treated as a full-time employee regardless of the employee’s number of hours of service during the stability period, so long as he or she remained an employee. The stability period cannot be less than the measurement period.

Administrative Period          

The administrative period includes all periods between the start date of a new variable-hour or seasonal employee and the date the employee is first offered coverage under the employer’s group health plan, other than the initial measurement period.  This provides a period of time to evaluate eligibility and to complete the benefit enrollment process.

Employment Status

What is required by the employer under the Affordable Care Act (ACA)?

The ACA requires employers to provide affordable health care that meets minimum essential value to substantially all full-time employees within 90 days of benefit-eligibility or face applicable penalties. 

Under the ACA what is considered full-time?

As defined in the ACA, the full-time employee is one who on average works 30 or more hours per week over the course of a 12-month look-back period (as illustrated in subsequent FAQ’s).

When does the Employee Shared Responsibility (ESR) Provision of health care reform to take effect?

The federal government requires tracking and reporting under the ESR as of January 1, 2015.  Coconino Community College will be required to offer medical benefits to at least 95% of their eligible employees beginning January 1, 2016.

Are only part-time and variable-hour employees measured?

All paid employees, regardless of their benefits eligibility or budget status will have a measurement and stability period. 

What hours are included in the hours reported for the measurement period?

All hours paid from all positions worked within the Coconino Community College is used to determine the average.  This includes hours worked such as: On call hours, vacation, holiday, sick leave, jury duty, military leave, etc.  Additionally, certain non-paid time must not be counted against the employee such as unpaid FMLA, military leave, or academic breaks including summer. 

What happens if an employee is paid for an average of 30 hours or more during the measurement period but reduces paid hours to less than 30 during the stability (benefits) period? 

Any employee who qualifies for benefits during a measurement period becomes eligible for benefits during the following stability period without regard to how many hours are paid during the stability period.

If an employee has a break in service (termination/rehire or layoff/recall) are they treated as a new hire or an ongoing employee when they return to work?

A “break in service” means a period during which an employee is not credited with any hours of service.  The duration of the break in service will determine the impact on the applicable measurement period.

• Break is greater than 26 weeks - treat as a new hire with a new initial measurement period.
• Break is less than 26 weeks, but more than 4 weeks AND the duration of the break is GREATER than the most recent period of employment – treat as a new hire with a new initial measurement period.
• Break is less than 26 weeks, but more than 4 weeks AND the duration of the break is LESS than the most recent period of employment – continue current measurement period without break in service factored into average.  Example: employee with 18 months of service has a 2 month break in service during the measurement period.  The hours paid for averaging will be averaged by 10 months instead of the standard 12 months.
• Break is 4 weeks of less – continue current measurement period including zero hours for break.  CAUTION: certain types of leave may not be counted against the employee.

I was a full-time CCC employee who has recently retired/terminated and would like to come back to work within CCC as a part-time employee.  Are there any special considerations I need to be aware of? 

Full-time employees who separate their employment and would like to work for CCC in a part-time capacity (hourly, contract or Part-time faculty) will only be eligible to be hired into such an assignment after a minimum of 6 months have passed from their retirement/separation date.  Retirees are also encouraged to consult with the Arizona State Retirement System (ASRS) for any limitation related to additional work and their retirement benefits.

Does CCC allow multiple position employment? 

CCC does allow for multiple position employment per HR Procedure 444-07.  The following conditions must be met:

• Employees are limited to working no more than two (2) positions at the college. 
  • Primary Position is either:
    • Hourly Part-Time Staff
    • Part-Time Faculty
• Secondary Position can be either:
  • Hourly Part-Time
  • Blended Positions which can be combined up to allotment provided by Compliance Specialist.
    • Committee Representative (College Council, Compensation, Faculty Senate)
    • Course Design/Curriculum Development
    • Employee Development (CARE Training, EDD, etc.)
    • EMT Exam Crew
    • Field Trip Driver
    • Fire Science Training Personnel
    • Goodwill Instructor
    • Interpreter
    • Mentor
    • Substitute

Part-time Blended Hours Guide

Measurement

 ACA Measurements PDF