Affordable Care Act (ACA) Compliance

To maintain the consistency necessary for ensuring full compliance with the Affordable Care Act (ACA), the following will be observed:

• The Initial Measurement Period will be 12 months1 after the first of the month following the date of hire.
  
  (For example, employees hired any day in September will be measured from October 1 of the year hired through September 30 of the following year.)
  
  

• The Administrative Period will be one month1 after the Initial Measurement Period.
  
  (For example, employees hired any day in September will be evaluated from October 1 through October 31 of the following year and offered group health insurance if they worked an average of at least 30 hours/week between the previous October 1 and September 30.)
  
  

• The Stability Period for will be 12 months1 after the Administrative Period.
  
  (For example employees hired any day in September who are offered insurance during the Administrative Period will be offered insurance from November 1 through October 31 of the year following their hire date. After that, they will be considered an Ongoing Employee2.)

• Employees transitioning from full-time to part-time status will have a Monthly Measurement Period and will be offered group health insurance for three full months after their transition date.

• Employees transitioning from part-time to full-time status while in their Initial Measurement Period will follow the same rules as newly hired full-time employees.

• Ongoing employees who transition from part-time to full-time will be offered group health insurance if they are determined eligible after a Standard Measurement/Lookback Period. 

• The Standard Measurement/Lookback Period will be from October 1 through September 30.

• The Administrative Period will be October 1 through December 31.

• The Stability Period will be the Calendar Year (January 1 through December 31).

The following rehires will be treated as newly hired employees: 

• Employees rehired into any position after 13 consecutive weeks of a break in service.
  
  (For example employees terminated in January and re-hired in June will be offered insurance starting August 1 if the position is one which averages 30 or more paid hours per week but will not be offered insurance if position is one which averages less than 30 paid hours per week.)
  
  

• Employees rehired into any position within 13 weeks of termination date (or retirement date with KERS), when the absence was longer than four (4) weeks AND longer than the period of employment (rule of parity).
  
  (For example employees hired on January 5, terminated on February 10 and rehired in June will be offered insurance starting August 1 if the position is one which averages 30 or more hours per week but will not be offered insurance if  the position is one which averages less than 30 hours per week.)

Rehired employees who are not considered to be new hires will resume any measurement or stability period they were in prior to termination  If they were enrolled in coverage during a stability period prior to termination, they will be offered insurance beginning with the first day of the calendar month following a resumption of services.

(For example employees hired on January 5, terminated on March 1, after group health coverage or HRA waiver began, and rehired on April 10 will be re-enrolled in the same plan they had starting May 1.)

NKY Health will use the “W-2 INCOME” safe harbor for the purposes of determining affordability of insurance plans.