ACA compliance has been top of mind for employers for some time now. Many are just now beginning to fully comply with all the ACA requirements, usually as a result of receiving either a non-filing letter (Letter 5699) or a proposed penalty notification (Letter 226J). Educational institutions are no exception. We continue to be approached by colleges to help with their ACA compliance needs because we understand the complexities that apply to the educational industry.
Educational institutions have some special circumstances that affect ACA compliance:
- Tracking hours doesn’t occur for adjunct faculty and graduate students.
- Tracking employment periods is difficult, especially considering the rules around the 26-week break-in-service.
- Impacts of summer breaks on employee eligibility is not easily understood and applied to compliance activities.
Understanding ACA Regulations for Colleges
The IRS has provided some guidance on how to infer the proper number of hours towards eligibility based on the number of hours that a professor spends in class. However, performing these calculations properly in assessing “hours of service” has proven challenging for employers.
Additionally, the ACA compliance regulations require educational institutions to use the original employee date of hire to determine health insurance eligibility when the break-in-service is less than 26 weeks. Tracking employment periods, and determining when to use a specific hire date has been difficult for the HR teams at institutions for higher learning.
Finally, the regulations require employers to ensure they don’t penalize employees that take seasonal breaks (summer/winter). As such, employers must either ignore those work periods or impute hours to those employees during the break period. Again, these present special challenges for educational institutions in complying with the ACA.
The good news is that we have lots of expertise in this area and are here to help. First, we suggest you review acafluent.com to get up to speed on all things ACA. Then sign up for a free 30-minute consultation, and we’ll do our best to help you with all your ACA compliance needs.