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PPACA guidelines for who qualifies for medical benefits

Below are further guidelines on the employee classification groups whose benefits eligibility is changing due to the Patient Protection and Affordable Care Act (PPACA). Note that this is an evolving situation, and this page will be updated as more guidelines are issued and the rules are clarified.

Exchange Notice for New Hires

  • Business offices need to provide an “Exchange Notice for New Hires” to all new and rehired employees at the time of I-9 certification. As of right now, it is a requirement that everyone has health insurance effective Jan. 1, 2014, and this notice will fulfill our employer requirement to inform these employees of their options. This is the most efficient way to relay the information in a timely manner.
  • The revised “Exchange Notice for New Hires” can be viewed here.

Undergraduate and graduate student employees

  • Student employees must be treated as any other temporary employees when determining eligibility for medical benefits under PPACA. PPACA does not provide any special exemption or treatment of student employees at this time.
  • Medical benefits will need to be offered within 90 days to students working an average of 30 hours or more a week.
  • Undergraduate hours will need to be tracked to prove that they are working an average of fewer than 30 hours a week.
  • It is legally permissible to indicate via a job description that hours are not to exceed some amount below 30 hours, but the hours will still need to be tracked.

Graduate student employees

  • Student employees must be treated as any other temporary employees when determining eligibility for medical benefits under PPACA. PPACA does not provide any special exemption or treatment of student employees at this time.
  • Medical benefits will need to be offered within 90 days to grad staff working an average of 30 hours or more a week.
  • Graduate students are still being discussed. For now, CUL will be used to estimate the hours already worked during the measurement period.

Resident Assistants (RAs) and Staff Residents (SRs)

  • Work is not easily translated into a set number of hours per day or week, but availability is required for about 12 hours, four days a week.
  • They may be required to return to their halls, even when they are off duty, to deliver emergency messages.
  • They are given a stipend, which includes a cash portion, tuition remission, housing and meals and are considered employees of Purdue.
  • Their positions are currently classified as ¼ CUL, which means they are not receiving benefits at this time; however, if they were tracking all the hours they were "on duty," they would be working more than 30 hours a week. Time sleeping and in their residence hall while "on duty" is currently being considered as working time.
  • This rule is a work in progress and may be amended later. For now, though, Purdue plans to put them into the graduate student insurance plan.

Temporary employees

  • This is a work in progress, and further research will need to be done before rules are finalized.
  • Hours will need to be tracked for this population. If they are found to be full-time under PPACA, they will be offered medical benefits only, beginning Jan. 1, 2015.
  • Beginning December 2014, if the intent at their date of hire is to have them work 30 hours or more per week, they will need to be offered medical benefits within 90 days.
  • Tracking will be done through a 12-month measurement, or look back, period. If the temporary employee is found to have worked 30 hours or more per week on average during that time, the employee is considered a full-time employee under PPACA and needs to be offered medical benefits during the subsequent stability period, which will last the same amount of time as the look back period. The stability period is the time following the measurement period when an employee has medical benefits that were earned the preceding year.
  • Special rules apply if the number of hours a temporary employee will work is uncertain at the time of hire:
    • If the variable-hour or seasonal employee works an average of 30 hours or more per week during the measurement period, the employee would be treated as a full-time employee beginning with the subsequent stability period.
    • If the employee works fewer than 30 hours a week on average during the measurement period, the employee would not be considered a full-time employee and would not have to be offered health benefits during the subsequent stability period.

Limited Term Lecturers (LTLs)

  • Until further guidance is issued, Purdue must use a reasonable method for calculating LTLs' hours of service, which must include all hours worked (including preparation for class, grading papers and other activities outside the classroom).
  • The reasonable method being deployed by many universities is to assume a 3:1 ratio – for every one credit hour taught, the LTL will be credited with three hours worked. For courses taught during the summer, a 5:1 ratio will be used. This means that for every one credit hour taught, the LTL will be credited with five hours worked.
  • An LTL offer letter has been created. Departments may put the offer letter into their own format; however, the highlighted portion of the offer letter must be used as it appears in the template. To view the template, click here.

FAQs

NOTE: These are the answers as of Dec. 17, 2013, but they are subject to change as health care regulations are amended and our administration makes final decisions. Also, please be advised that Human Resources is working on a system to track eligibility to aid departments with this endeavor.

Eligibility

Measurement Period

Decrease in Hours

Other