Affordable Care Act Implications for Student Employees

In calendar year 2016, requirements for employers under the Affordable Care Act (ACA) will be changing. In calendar year 2015, employers are required to offer health insurance to 70% of their full-time employees. In 2016, the ACA requires employers to offer health insurance to 95% of their full-time employees. Under the ACA a full-time employee is anyone who works 30 hours per week.

This presents some challenges for all of UW, including UWM. If no action is taken, the UW will not make the 95% required threshold of full-time employees to be offered health insurance and may face enormous fines.

One specific challenge involves student employees. The UW is not statutorily permitted to offer health insurance to student employees. This means we cannot allow student employees to be defined as full-time employees for ACA purposes. As such, a UW System-wide policy regarding student employment, effective January 1, 2016, has been created that includes:

Limiting student employees to 25 hours per week during the 39-week academic year (the 39-week academic year at UWM runs from late August through mid-May)
The hour limit is aggregate across all student jobs. Students may not work more than 25 hours per week in total, no matter how many student jobs they hold.
Hours worked under the federal work-study program do not count toward the 25 hour per week limit
Eliminating lump sum pay for student appointments, as lump sum appointments are considered full-time employment under the ACA
Student employees may work full-time in the weeks of the year outside the 39-week academic year
I encourage you to direct questions about the UW System policy regarding student employment to your supervisor so you understand the changes effective January 1, 2016.

Thank you,

Timothy J. Danielson
Associate Vice Chancellor – Human Resources
University of Wisconsin Milwaukee

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