Affordable Care Act (ACA) and Benefits Eligibility
Young Life provides valuable health benefits to all eligible employees. Under the Affordable Care Act (ACA), certain employees who previously weren’t eligible to enroll now have the privilege of enrolling in our plan.
Budgeting
Each area or mission unit should budget in anticipation of every eligible employee enrolling themselves and their qualifying family members into the Young Life plan. Even though an employee may opt out of our coverage, circumstances may arise down the road that would require enrollment in our plan. Be prepared!
Enrollment and Opting-Out
The Young Life Benefits Plan requires enrollment for all eligible employees and their immediate family members. Although employees may opt out of our plan if they have other qualifying coverage, supervisors should in no way discourage employees from enrolling in our plan or encourage them to enroll into another plan.
Frequently Asked Questions
ACA rules are complicated. The Q&A below provides explanation for scenarios such as:
- Transfers from one mission unit to another.
- Changes in status.
- Rehires.
As a brand-new employee, Young Life offers coverage to all regular full-time employees (i.e. working 40 hours per week) and those part-time employees designated as working 30 hours per week.
For new hourly employees NOT designated as working 30 hours per week, their hours will be measured after 11 months of employment to determine if they’ve reached the average for benefits eligibility (see FAQ #2).
Seasonal and temporary employees are not offered coverage initially regardless of anticipated hours worked. However, if a seasonal or temporary employee is still on staff after 11 months, their hours will be measured to determine benefits eligibility AND their status may need to be changed. This might occur if a seasonal employee at one camp transfers to another camp.
There are two measurement periods to determine whether an employee is benefits-eligible:
Initial Measurement Period (IMP) – the first 11 months of employment or following a rehire after a 13-week minimum break in service.
Standard Measurement Period (SMP) – October of the prior year through September of the current year.
Following the applicable measurement period, employees are in a full-time or part-time stabilization period regardless of hours worked going forward (as long as they remain employed):
Stabilization Period – the 12 months that an employee is designated as full-time or part-time by reason of an Initial or Standard Measurement Period. Based on the full-time or part-time designation, employees are benefits-eligible or not for the designated 12-month period.
Right. Working 29 hours a week over the course of the Initial Measurement Period or during the Standard Measurement Period does not reach the 130-hour-per-month threshold, and therefore, the employee would NOT be eligible for health benefits.
Benefits are effective on the first of the month coinciding with, or following, date of hire/rehire or transfer to an eligible status, whichever comes first. For those gaining coverage because of the number of hours worked during an Initial Measurement Period, they become benefits-eligible after a 31-day “trailing” period.
For those employees who gain benefits eligibility as a result of the annual Standard Measurement Period, they will be offered coverage on January 1 of the following calendar year.
Yes. During the last Standard Measurement Period, the employee averaged 40 hours per week as a regular, full-time employee. As a result, the employee is in a full-time stability period for the current plan year which ends on December 31. Depending on when the employee transferred to part-time, the employee may also be eligible for the following plan year if the full-time and part-time hours average 130+ hours per month for the current measurement period.
Example:
John worked full-time from October 2020 through September 2021, gaining a “full-time” stability designation for 2022, because his hours averaged over 130 per month during that Standard Measurement Period. Then on May 1, 2022, he transferred to a new area, only working 20 hours per week. Since his stability designation for 2022 was already “full-time”, he continues to be benefits-eligible through 2022 – even though he is only working 20 hours per week.
And since he worked full-time hours from October 2021 through April 2022, he will also meet the 130-hours-per-month average during the upcoming Standard Measurement Period and will continue to be benefits-eligible for all of 2023. If he continues at 20 hours per week through 2023, then he will lose his eligibility as of 12/31/2023 as he won’t meet the required number of hours for the following Standard Measurement Period.
If an employee has a change of status during the first 11 months of employment, whatever status he/she transfers to will determine benefits eligibility. This time is referred to as the “Initial Measurement Period” as outlined in FAQ #2.
Example:
Julie was hired on May 1, 2021 as a part-time employee working 20 hours per week – she was not benefits-eligible at that point. However, on October 1, 2021, she transferred to a new area working 30 hours per week – she then became eligible for benefits.
Conversely, if Julie was hired on May 1, 2021 as a regular, full-time employee working 40 hours per week, she was benefits-eligible. If she then transferred to a new area working 20 hours per week as of October 1, 2021, she would have lost her benefits eligibility, and her coverage would have cancelled on September 30. She was in her “Initial Measurement Period” and had no stability designation, so the transfer to part-time staff caused her to lose benefits eligibility.
Yes. Under the provisions of the Affordable Care Act, any employee who has a break in service less than 13 weeks retains his/her stability designation in place prior to the break in service. In this case, his stability designation was “full-time” for 2021 and 2022, so he keeps his benefits eligibility until Dec. 31, 2022.
Example:
Devin was a full-time employee from October 2014 through August 2021. When his hours were measured from October of 2019 through September of 2020, his designation was “full-time” for his “stability period” of 2021. (He lost his coverage as of August 31 when he went off staff.) Since he returned to staff within 13 weeks, he kept his “full-time” designation for the remainder of 2021 and went back on benefits October 1, his rehire date. For 2022, his hours worked between October of 2020 and September 2021 were measured. Since that average still exceeded 130 hours per month, he continues to be benefits-eligible through 2022 (his stabilization period). If he continues working only 25 hours per week through 2022, he will lose his eligibility as of 12/31/2022.
If Devin was off staff for at least 13 weeks and came back as a part-time employee working 25 hours per week, he would NOT be benefits-eligible until he earned that designation by working an average of 130 hours per month during a measurement period (initial or annual).
No. Based on her last Standard Measurement Period (October 2020 through September 2021), her average hours worked for that time period qualified her as “part-time” for all of 2022 (her stability period). And because she’s only worked 120 hours per month from October 2021 through February 2022, her designation will still be “part-time” for all of 2023, because the 130 hours per month from March through September still don’t bring up her monthly average to 130 by the end of September. If she continues to work 130 hours per month during 2023, she will become benefits-eligible as of January, 2024.
Note: Any time an employee transfers to a regular full-time position, he or she becomes benefits-eligible on the first of the month coinciding with, or following, the status change (whichever comes first.) This is Young Life’s standard practice, and because it is more generous than the Affordable Care Act provisions, it is allowed.
No, we cannot waive the requirement to offer her coverage. Based on her last Standard Measurement Period (October 2019 through September 2021), her average hours worked for that time period qualified her as “full-time” for all of 2022 (her stabilization period), and she is benefits eligible through December 31, 2022. As for opting out, she may do so only if she has qualifying coverage as outlined here. An employee cannot opt out by purchasing private coverage elsewhere such as Medi-Share or a plan from the insurance marketplaces.
Work schedules for all variable-hour employees should be monitored to determine if the employee will become benefits eligible during the next measurement period so budgets can be modified accordingly.
Unfortunately, no. The only way to keep her on benefits when she’ll have a part-time stability designation for 2023 is to transfer her to a regular, full-time position. Otherwise, she will be offered Continuation Coverage (our church version of Cobra) at her own cost. Please note that mission unit funds cannot be used to pay for these premiums.
Administering the provisions of the Affordable Care Act is very complicated, and employees may have their measurement periods affected by certain types of leaves and breaks in service. We encourage you to contact contact the Benefits department with questions and to talk through specific scenarios: 719-381-1950.