The Higher Ed Workplace Blog

IRS Issues Final Regs for Calculating Adjunct Faculty Hours and More

irs-logoYesterday, 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.

Other reading:  summary fact sheetfull rule.