SUBJECT:

Affordable Care Act Employer Shared Responsibility Requirements

In compliance with the Affordable Care Act (ACA), new benefits eligibility regulations are taking effect in January 2016 for University of California (UC) employees that have historically been excluded from medical insurance benefits eligibility.

Beginning January 1, 2016 and beyond, the new benefits eligibility rules require that all UC employees working an average of 30 hours per week for three months or more during a measurement period be offered at least a Core Benefits Package. The offer applies to the following appointment types: per diem employees, students in casual/restricted appointments, seasonal workers, and those compensated solely by agreement (flat-dollar compensation). The UC Office of the President will contact eligible employees by December 31, 2015 to offer them Core Benefits and inform them of a special enrollment period in January 2016.

The ACA requires that full-time employees are offered coverage, however, it does not require that the employee enroll in a plan. For example, an eligible employee may be offered coverage but decline the coverage because the employee is covered under the medical plan of a spouse, parent or domestic partner.

While the changes will take effect January 1, 2016, the determination of eligibility is based on a calculation of hours worked during a 12-month look-back measurement period which started in November 2014. Consequently, employees in the ineligible categories may qualify for UC insurance in 2016, based on their 2015 employment history. The retrospective calculation and determination of eligibility will occur annually and will be administered automatically in the Payroll Personnel System.

The changes may result in an increase in benefits costs to departments in calendar year 2016 and beyond if employees in the eligible job categories meet the benefits eligibility criteria during subsequent measurement periods. When considering a future budget plan, departments should keep in mind that going forward, benefits eligibility for employees may continue for a longer period of time.

Complete details on the new provisions impacted by the ACA regulations, including UC employer shared responsibility requirements, can be accessed at the UC Net website: http://blink.ucsd.edu/go/aca. Additional information is provided in the Frequently Asked Questions section at: http://ucnet.universityofcalifornia.edu/oe//faq/aca-faq.html.

Robert A. Crouch Assistant Vice Chancellor - Campus Human Resources Cynthia M. Palmer Assistant Vice Chancellor - Academic Personnel Services Janet Kamerman Interim Assistant Vice Chancellor - Health Sciences Human Resources