Affordable Care Act

The federal Affordable Care Act (ACA) requires changes in workforce management and payroll procedures. The ACA redefines "full-time employee" and changes how benefits eligibility is determined. These changes impact nearly every university department. Maintaining compliance requires collaboration between individual departments, Payroll and Employee Services, Human Resources, and several other university offices.

In 2018 OU implemented a centralized time system for Norman campus employees, this has changed the way in which employee time is entered and tracked for ACA eligibility. All employees in a monthly appointment will have defaulted ACA hours based on their FTE, this is shown as the pay code “Work Elapsed”; for example: "if an employee is half-time (0.50 FTE) their default value will be 4-hours per working day". This transition removes the need for employees to submit an ACA Tracking Log to be entered manually in association with monthly compensation.

Hourly employees' ACA hours are calculated based upon hours in which they are paid.

If an employees’ worked hours are greater or less than their Work Elapsed hours in Workforce the employee has the ability to personally update the value for each day to accurately account for all time worked for ACA eligibility.

Notice: falsification of timesheets, whether submitting or approving, can be grounds for immediate termination.

Graduate Assistants (GA's): Time in Workforce is defaulted based on your FTE, the defaulted “Work Elapsed” value includes any time assisting with course structure and presentation/teaching. For Graduate Research Assistants and Graduate Teaching Assistants who are not Instructors of Record, ACA hours of service are based 20 hours per week for those at the 0.50 FTE appointment level, and 28 hours per week for those at the 0.70 FTE appointment level. For Graduate Teaching Assistants who are Instructors of Record, you may update your defaulted hour value to account for additional time spent on office hours or in faculty meetings, to do so please use the Safe Harbor method provided in the chart below.

Also, please review the Student Employees and the Affordable Care Act document listed at the bottom of this page for more information regarding GA appointments and ACA policy.

Adjuncts: Time in Workforce is defaulted based on your FTE, the majority of Adjuncts hold a 0.10 - 0.25 FTE. If needed you may update your defaulted hours to account for additional time spent during instruction please use the chart below:

Managers, supervisors, and payroll coordinators can help meet these requirements by taking the following actions.

1. Review the ACA requirements in the documents below. Share the ACA documents listed below with other supervisors and managers as needed. These details refer to Norman programs. A link for HSC programs has been provided.
   
2. Update payroll reporting processes where needed (see summary below).
3. Understand the additional cost of providing employee medical insurance to employees meeting the ACA definition of full-time employee (see summary below).
4. After reading the related workforce management documents, please contact the ACA Analyst in payroll with further questions.  

The ACA defines "full-time employee" as any employee who averages 30 hours or more per week. The ACA requires that the university report hours for all employees and offer employee medical insurance to employees who meet the ACA definition of full-time employee. The ACA reporting requirements require new departmental record-keeping procedures for most employees, except full-time benefits eligible employees (0.75-1.0 FTE). Review the related Workforce Management documents below.

When an employee meets the ACA definition of full-time employee, Payroll and Employee Services will notifiy the Human Resources Benefits department to offer eligible employee's medical insurance without further action from the department and regardless of the employee's category in the OU payroll system. This may change the employee's payroll category. The university benefits fringe rate applied to this employee will change to cover the additional cost of providing medical insurance.

ACA eligibility is basd upon worked hours averages during a specific period of review. A new employee will be reviewed  2-times during their first year of employement, confirmed eligibility lasts 1-year unless found to be eligible under a consecutive period, which, would extend ACA eligibility by an additional year from the effective date. All employees are subject to the rules and regulations of the Affordable Care Act regardless of their employment type (Fulltime or Parttime). Employees will be notified of ACA healthcare eligibility if they average 30+ hours per week during any of the 2 review periods listed below:

    Standard Measurement Period (SMP)

During the Standard Measurement Period (SMP) all University employees are measured for ACA elgiibility. The SMP has a static measurement period anually, each period will begin on November 1st of the current year through October 1st of the following year, exmple: 11/1/2018-10/31/2019.

If an employee averages 30 or more hours per week during this time they will become eligible for ACA coverage and will be offered January 1st of the following year. The timeline for processing is listed below:

Measurement: November 1 - October 31 (initial year)

Review/Offer (Administration) Period: November 1 - December 31 (initial year)

Coverage Begin Date: January 1 (following year)

    Initial Measurement Period (IMP)

During the Initial Measurement Period (IMP) all new University employees are measured during their first year of employment for ACA elgiibility. The IMP is calculated monthly. For example, if an employee is hired during June (2018) the measurement period will be 7/1/2018-6/30/2019, if found eligible the employee will be offered coverage beggining August 1st, 2019.

If an employee averages 30 or more hours per week during this time they will become eligible for ACA coverager. The timeline for processing is listed below:

Measurement: Month of Hire + (12 month measurement period)

Review/Offer (Administration) Period: Month following end of measurement period

Coverage Begin Date: The first of the month after the review period

For additional information regarding ACA rules and regulation please visit the IRS website at www.irs.gov. Please visit the Norman Human Resources website for additional ACA informaiton related to HSC programs and forms.