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Implementation Issues for Kentucky School Districts. Affordable Care Act. Presenters. Melissa Sullivan 502-564-3930 extension 4415 Susan Barkley 502-564-3930 extension 4437. Resources.

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Affordable Care Act

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Implementation issues for kentucky school districts

Implementation Issues for

Kentucky School Districts

Affordable Care Act



  • Melissa Sullivan

    502-564-3930 extension 4415

  • Susan Barkley

    502-564-3930 extension 4437



  • KDE website: Health and Life Insurance Benefits and Flexible Spending Accounts page


    • Implementation Guide

    • Timekeeping documentation

    • KEHP FAQs and Responsibility Chart



  • The Guide is only one of many resources

  • IRS continues to issue regulations on ACA

  • Information in the Guide could become inaccurate

  • Not comprehensive of all aspects of ACA

  • Consult legal counsel

Whose responsibility

Whose Responsibility?

  • Districts:

    • Eligibility and offers of coverage (Play or Pay)

    • Nondiscrimination

    • Marketplace Notice

    • Employer Reporting

  • KEHP:

    • Affordable coverage

    • Adequate coverage

    • Plan details and options

Affordable care act

Failure to comply = PENALTY

Affordable care act

The ACA seems like a mountain

Affordable care act

But KEHP is taking care of compliance with affordability and adequacy requirements

Affordable care act

And MOST employees are already receiving health benefits, including bus drivers

Affordable care act

And we know many variable hour employees won’t work enough separate days at 8 hours a day to change their eligibility status – therefore we don’t need to track their actual time

Affordable care act

So the work we have to do for ACA isn’t as big a mountain as we expected

What do we have to deal with

What do we have to deal with?

  • Establish policies relating to ACA

  • Track actual time for employees close to the eligibility break point and part-timers

  • Calculate eligibility for all variable hour employees

  • Document offers of coverage

  • Provide marketplace notice to new hires

  • Ensure nondiscrimination

  • Employer reporting to IRS

Who do we need to worry about

Who Do We Need to Worry About?



  • If employee is expected to work full-time must offer coverage at the time of hire

  • If it is unknown if the employee will have an average of 30 service hrs/week or 130 service hrs/month, use the measurement period

Action steps

Action Steps

Repeat Annually

Who are employees

Who are Employees?

An employee relationship exists when the employer has the right to control and direct the individual who performs the services and the details and means by which the result is accomplished.

Who are employees1

Who are employees?

Large employer

“Large” Employer

  • 2015 = 100 or more FT & FTEs

  • 2016 = 50 or more FT & FTEs

  • Most KY school districts are large

Hours of service

“Hours of Service”

  • Hours actually worked (or equivalency)

  • Hours paid or entitled to be paid

    • Vacation

    • Holiday

    • Sick leave

    • Disability

    • Jury duty

    • Military duty

Equivalency hours

Equivalency Hours

Employment breaks

Employment Breaks

  • Breaks at least 4 consecutive weeks in length

  • Cannot count zero hours worked

  • Exclude from average hours of service

    Examples: summer break, FMLA leave

Eligibility break point

Eligibility Break Point

  • Step 1 – calculate number of days excluding breaks of > 4 weeks

  • Step 2 – multiply 5.997 by the number of days from Step 1 and then divide by 8

    5.997 * 207 / 8 = 154 days

Do i need to track actual time

Do I need to track actual time?

  • To limit the number of employees tracking actual time worked:

    • Limit number of days/year

    • Limit number of days/week

    • Use equivalency of 8 hrs/day

Board action

Board Action

  • Measurement, administrative, and stability periods

  • Limitation of days worked

  • Track actual hours or use equivalency

  • Terminate subs that refuse


Full time employees for aca

Full-time Employees for ACA

Employees who average

30 hours of service per week or

130 hours of service per month

Who is full time

Who is Full-time?

Average hours of service over measurement period

  • Max 12 months

  • Recommended:

    October 3, 2013 – October 2, 2014

  • Don’t forget to exclude breaks >4 weeks

Recommended measurement periods

Recommended Measurement Periods

Continually measuring

What about mid year hires

What About Mid-Year Hires?

  • InitialMeasurement Period

    • Begins the first day of the month after hired

    • Max 12 months

    • Transitions to standard measurement period

Initial measurement period

Initial Measurement Period

Note that the standard measurement period begins during the initial measurement period; both periods occur simultaneously

Offering coverage

Offering Coverage

  • ACA requires coverage for full-time employees and dependent children – not spouses

  • Coverage must begin Jan 1, 2015 for districts with 100 or more full time & FTEs

  • Coverage must begin Jan 1, 2016 for districts with 50 or more full time & FTEs

  • Offer must be made, employee can decline

  • Maintain documentation

  • Annual requirement

Offering coverage1

Offering Coverage

  • Full-time during Measurement Period = Coverage during Stability Period regardless of hours of service during Stability

  • NOT full-time during Measurement Period = NO coverage during Stability Period regardless of hours of service during Stability





  • State funds non-federal employee premiums

  • If health insurance appropriation is inadequate, unexpended SEEK funds may be used

  • Avoid a blanket policy to offer coverage to all employees



  • If no Substantial Compliance

    • For 2015 - 70% of full-time employees

    • Starting in 2016 - 95% or no more than 5 full-time employees

  • Penalty is

    • Number of full-time employees minus 30

    • Multiplied by $167 per month



  • Cannot provide more for highly compensated employees

  • Example: paying the superintendent’s employee premiums

  • Penalty is

    • Number of employees minus the superintendent

    • Multiplied by $100 per day until in compliance

  • Solution: tax the additional benefit

Employer reporting

Employer Reporting

  • Will be required

  • First report due March 2016 for 2015 plan year data

  • IRS guidance not finalized

  • More information forthcoming

Your good questions

Your Good Questions

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