Subject: PPACA Tracking Requirements for Contract Semester Faculty and Graduate/Doctoral Assistants Working in Academic Departments
Dear Academic Administrators, Deans, and Department Chairs,
As you may be aware from the guidelines communicated to you in Dr. Randy Howard’s email message of December 3, 2013, the Patient Protection and Affordable Care Act (PPACA), requires the University to offer health care coverage by January 1, 2015 to employees who average 30 or more hours of work per week over a set measurement period. This message is intended to supplement Dr. Howard’s message and provide specific details about your responsibilities as they relate to the hiring and employment of contract semester faculty and graduate/doctoral assistants.
The University has defined our first measurement period as the 12 month period beginning on October 6, 2013 and ending on October 5, 2014. For faculty, credit loads will be assessed using these semesters: Spring 2014, Summer 2014, and Fall 2014.
The University must either track actual hours of service or utilize a reasonable method for determining and tracking hours of service for employees.
By the start of Spring Semester 2014 graduate/doctoral assistants will begin tracking actual hours of work using Kronos, and contract semester faculty’s hours of service will be calculated using the reasonable method formula that 1 credit hour equals 3 hours of service.
Therefore, effective immediately, we require you to do the following:
Contract Semester Faculty:
• Closely monitor course loads to ensure contract semester faculty do not teach more than a 9 credit hour load during the Spring, Summer, and Fall 2014 semesters;
• Under the reasonable method formula available for the 2014 transitional period, contract faculty are not required to track hours of service; however, they must be limited to 9 credit hours per semester.
• Do not give or authorize additional or secondary assignments without prior approval of the provost. If approved by the provost, such assignments may not exceed 2 hours per week. For example, some contract semester faculty may have historically had additional assignments within the department working as advisors or preparing the departmental newsletter, or may have held secondary positions outside the department working during summer orientation or as ticket-takers/ushers at athletic events. All hours of work from additional assignments or secondary positions must be included when determining total hours of service per week;
• Do not permit contract semester faculty to cover classes for other absent faculty.
• Closely monitor work assignments to ensure graduate/doctoral assistants do not average more than 29 hours of service per week;
• Require graduate/doctoral assistants to begin tracking actual hours of work and report such time in Kronos following the bi-weekly pay period cycle;
• Contact your SuperAdmin to arrange Kronos training for your graduate/doctoral assistants;
• Departments are responsible for ensuring graduate/doctoral assistants time reported in Kronos is correct and signed off on at the conclusion of each bi-weekly pay period.
The payroll schedule may be found at this link: http://cms.bsu.edu/-/media/WWW/DepartmentalContent/Payroll/PDFs/2014%20GA%20Payroll%20Schedule.pdf.
If you have questions about PPACA or your role in assuring compliance, please contact Judy Burke at 285-1834 or Melissa Rubrecht at 285-1823.
Please note, too, that these guidelines may prohibit work that is otherwise permissible according to the supplemental compensation policy.
In rare cases, because of the nature of the work, exceptions to these guidelines may be needed. In these cases, University Human Resource Services will work with the affected department on a case-by-case basis. These proposed guidelines may be subject to change and will be further refined at such time when final regulations are issued.
Marie Y. Williams
Associate Vice President for Human Resources
and Administrative Services
Ball State University