Effective January 1, 2015, the Patient Protection and Affordable Care Act (PPACA) requires large employers (50 or more employees) such as UNLV to offer health insurance benefits to any employee averaging 130 work hours or more per month.

Although this portion of the law does not take effect until January 1, 2015, the “measurement period” that will be utilized to determine employee eligibility for employer-sponsored health insurance benefits begins July 1, 2014. More details about the measurement period is provided below.

The Nevada System of Higher Education currently offers Health Insurance coverage through the Public Employees Benefits Program to employees in the following categories:

  • Temporary hourly employees at 50% FTE working at least 80 hours per month
  • Classified employees at 50% FTE working at least 80 hours per month
  • Academic and Administrative Faculty at 50% FTE
  • Employees on a Letter of Appointment with Benefits who are working at 50% FTE.

The benefits provided by PEBP meet the ACA’s requirements.

The following employees in the Nevada System of Higher Education do not meet eligibility requirements for coverage through the Public Employees Benefits Program if working less than 80 hours per month (49.9% fte or less)

  • Casual, Temporary, Seasonal employees
  • Student employees
  • Event center employees
  • Employee on a Letter of Appointment

For these employees, hours will need to be measured to determine benefits eligibility under ACA. It is essential for departments or units to monitor the employment of and hours worked by these employee types.

Under the ACA guidelines, each employer is responsible for tracking and monitoring employee status and ensuring that eligible employees are offered health coverage. The Nevada System of Higher Education has elected to use the following measurement periods under the ACA’s safe harbor rules to determine full time employee status for ACA purposes.

For ACA purposes, the following terms are defined as

Full time employee

Any employee of NSHE that provides one hundred and thirty (130) or more hours of service per month over an entire “Standard Measurement Period”. An employee who works at multiple NSHE institutions will be counted as one employee and their hours will be aggregated.

Hours of service is the time that each employee:

  • Performs work for the benefit of the employer
  • All hours for which employees are paid or entitled to be paid
  • All hours for which employees are entitled to be paid although they may not be performing labor for the employer. This includes time off for vacation, sick, military duty, or other leaves of absence where the employer has agreed to pay the employee.
Standard Measurement Period
A ten month period of time that NSHE will use to determine benefits eligibility under ACA. NSHE has elected a standard measurement period of July 1 to April of each year.
Administrative Period
A two month period after a Measurement Period when NSHE will review employee hours and determine eligibility as well as offer insurance to eligible employees.
Stability Period
A twelve month period where eligible employees who elect health care coverage maintain their coverage while employed even if their hours during this stability period falls under 130 hours per month.
Initial Measurement Period
A ten month period where a new hire’s hours are measured to determine benefits eligibility. An employee need to work an average of 130 hours during this period to be eligible for benefits.

Salaried Employees
They are credited with 8 hours of service for each day for which the employee is paid or entitled to be paid.
Hourly Employees
They are credited for 1 hour of service for each hour in which the employee is paid or entitled to be paid.
Academic Letter of Appointments
They will be credited the following:
  • 2.25 hours of service for each hour of class time
  • 1 hour of service for each hour spent for office hours or meetings
Resident Assistants
TBD
Independent Contractors/Leased employees
They are not considered employees of NSHE and are not eligible for benefits under NSHE.
Federal Work Study Program
Hours worked under this program do NOT count as “hours of service” under ACA.
Paid Leave (Vacation, Sick, Jury duty, etc)
It counts towards hours of service and should be credited in accordance with how the employee is paid.

To be eligible for benefits during a Stability Period, the employee needs to have worked an average of 130 hours per month during NSHE’s Standard Measurement Period (July 1 to April 30). If they meet this threshold, then they will be offered health benefits the first of the month following a two month administrative period. The employee is then able to keep that coverage for a full twelve months (stability period) while employed even if their hours during that time falls under 130 hours per month.

In order to keep their benefits after that first stability period, the employee needs to have worked an average of 130 hours during NSHE’s Standard Measurement Period (July 1 to April 30).

Example - Existing employee active as of July 1, 2014

  • July 1, 2014 UNLV will start tracking time (The measurement period will be July 1 – April 30 of each year).
  • The first measurement period begins on July 1, 2014 through April 30, 2015.
  • Employee needs to work at least 130 hours per month
  • During the administrative period of May 1, 2015 through June 30, 2015, the data will be reviewed to determine eligibility and notify employees who have become eligible for employer-sponsored benefits.
  • If an employee works an average of 130 hours per month during the measurement period, he/she must be offered employer-sponsored benefits for a period of time in the future known as the stability period.
  • The initial stability period will be from July 1, 2015 thru June 30, 2016. During this time, eligible employees who opt to receive employer-sponsored benefits will continue to receive the coverage regardless of hours worked during the stability period. Department will be charged a corresponding subsidy.
  • Annual reviews will continue thereafter using the standard measurement period.

For a calendar of the measurement periods, administrative periods, and stability periods for existing and new employees, click the button below.

To be eligible for benefits during a Stability Period, a new hire needs to have worked an average of 130 hours per month during their Initial Measurement Period. If they meet this threshold, then they will be offered health benefits the first of the month following a one month administrative period. The employee is then able to keep that coverage for a full twelve months (stability period) while employed even if their hours during that time falls under 130 hours per month.

In order to keep their benefits after that first stability period, the employee needs to have worked an average of 130 hours during NSHE’s Standard Measurement Period (July 1 to April 30).

Example new hire in August 2014

  • September 1 - UNLV will start tracking time (Measurement period will begin the first of the month following date of hire).
    • The measurement period will be a ten (10) month period from September 1, 2014 through June 30, 2015.
    • During the administrative period of one month, from July 1, 2015 through July 31, 2015, the data will be reviewed to determine and notify employees who have become eligible for employer-sponsored benefits.
    • If an employee works an average of 130 hours per month during the measurement period, he/she must be offered employer-sponsored benefits.
    • The initial stability period will be from August 1, 2015 thru July 31, 2016 for a period of 12 months. During this time, eligible employees who opt to receive employer-sponsored benefits will continue to receive the coverage regardless of hours worked during the stability period.
    • Annual reviews will continue thereafter using the standard measurement period.