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ACE Testifies on Insuring Adjunct Faculty and Student Workers Under ACA

April 24, 2013

IRS hearing


Steven Bloom, director of federal relations at ACE, testified at an April 23 hearing of the Internal Revenue Service (IRS) and the Treasury Department about proposed regulations which would affect coverage for adjunct faculty and student campus employees under President Obama's health reform law, the Patient Protection and Affordable Care Act (ACA).

The ACA requires large employers—including colleges and universities—to provide health benefits to employees who work 30 hours or more a week.

The IRS and Treasury released proposed rules in early January regarding when and to whom employers would be required to offer health insurance coverage. In determining whether colleges and universities are required to offer coverage to adjuncts, the proposed regulations advised institutions to use “a reasonable method for crediting hours of service," which should take into account work performed in and out of the classroom. The rules did not explicitly deal with the matter of student workers.

Bloom’s remarks summarized written comments ACE submitted in March in response to the proposed regulations.
Regarding adjunct faculty, Bloom testified that most often, institutions do not track hours worked but instead pay adjuncts per course, based on the specific course’s demands, including preparation time, in-class instruction time, and out-of-class responsibilities. He reviewed the two safe harbors ACE’s written comments urged the agencies to adopt, which he said will provide institutions and adjuncts a fair and reasonable method for managing their relationships consistent with the ACA’s requirements. 

Bloom also discussed ACE’s safe harbor proposals for students working on campus, who are generally paid by the hour or with a stipend and are not usually covered under college or university employee health insurance plans. In addition, he raised concerns about the potential adverse effect of the ACA on students participating in internship or cooperative educational programs and proposed a potential solution.

For more information on the hearing, see:

Adjuncts' Advocates Call for Fair Treatment on Work-Hour Calculations
The Chronicle of Higher Education (April 23, 2013)

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