IRS Issues Final Regs for Calculating Adjunct Faculty Hours and More
Yesterday, the Treasury Department and IRS issued final regulations for calculating adjunct faculty hours, as well as students in work-study programs, seasonal employees and other employee categories under the Affordable Care Act (ACA) for 2015. We’ve summarized below, but be sure to read CUPA-HR’s full write-up on the regulations for details on how they impact higher education institutions.
- Adjunct Faculty – The final regulations credit an adjunct faculty member with 2 ¼ hours of service per week for each hour of teaching or classroom time as a reasonable method for calculating time the adjunct spends on class prep and grading papers, but institutions also need to separately credit adjuncts for any additional mandatory out-of-classroom time, such as holding office hours or attending faculty meetings.
- Students in Work-Study Programs – Service performed by students under federal or state-sponsored work-study programs is exempt and will not be counted in determining whether they are full-time employees.
- Educational Employees – Teachers and other educational employees will not be treated as part-time for the year simply because their school is closed or operating on a limited schedule during the summer.
- Seasonal Employees – Those in positions for which the customary annual employment is six months or less generally will not be considered full-time employees.
The final rules also provide a gradual phase-in of the employer responsibility provisions (including the extension of 2014 transition relief measures) and assist employers in complying and providing coverage, methods for calculating full-time status, and affordability safe harbors. Treasury and the IRS will issue final regulations shortly that aim to simplify and streamline the employer reporting requirements.