NAICU Washington Update

IRS Provides Guidance on ACA Requirements for Adjunct Faculty/Student Employees

February 18, 2014

On February 10, the IRS provided long-awaited guidance for colleges and universities on defining the workload for adjunct faculty and student employees for purposes of health insurance coverage under the Affordable Care Act (ACA). The higher education community has been seeking this guidance since March of last year. While the information will help colleges account for workload hours, it is less clear that the guidance will answer all questions on when adjuncts are required to have health insurance under the ACA.

The ACA generally requires large employers to offer health insurance coverage to employees that work 30 hours or more weekly. It was unclear, however, how to count the hours of adjunct faculty in particular since a percentage of classroom-related work is often done off campus or outside of the classroom setting.

The IRS rules clarify ways to tally hours on tasks such as lecture preparation, teaching, grading assignments, as well as office hours. They also indicate that other acceptable accounting methods may be developed by institutions, and that additional guidance may be announced in the future.

Links to the IRS release, community letters, and other specifics, can be found here.