HomeMy WebLinkAboutItem 5k - Approve the Affordable Care Act Report and Temporary Employee Eligibility Policy Item 5k
Department: Human Resources
Cost Center: 3001
For Agenda of: 6/3/2025
Placement: Consent
Estimated Time: N/A
FROM: Nickole Domini, Human Resources Director
Prepared By: Amy Fletcher, Human Resources Analyst
SUBJECT: APPROVE THE AFFORDABLE CARE ACT REPORTING AND
TEMPORARY EMPLOYEE ELIGIBILITY POLICY IN COMPLIANCE WITH
THE AFFORDABLE CARE ACT
RECOMMENDATION
1. Adopt a draft Resolution entitled, “A Resolution of the City Council of the City of San
Luis Obispo, California, adopting the Affordable Care Act Reporting and Temporary
Employee Eligibility Policy.” (Attachment A)
2. Authorize the City Manager to make future administrative changes to the policy as
deemed necessary to remain compliant with Affordable Care Act.
POLICY CONTEXT
The Affordable Care Act Reporting and Temporary Employee Eligibility Policy formalizes
the City’s compliance with the Affordable Care Act. On October 1, 2013, the City Council
approved Resolution #10461 adopting policy guidelines to comply with Affordable Care
Act that went into effect for coverage starting January 1, 2015. In the event of an audit,
the City will be able to present this policy as evidence of compliance with the Affordable
Care Act.
DISCUSSION
Background
The federal Affordable Care Act (hereinafter referred to as “ACA”) became law in March
2010. Implementation of this complex legislation was phased in from 2010 through 2018,
requiring employers and insurance companies to make necessary changes to remain in
compliance. A significant aspect of the ACA that went into effect in January 2015 is
referred to as the Employer Shared Responsibility Provision, or more commo nly known
as the “Play or Pay Mandate.” This provision of the ACA assesses penalties for all large
employers (defined under the ACA as employers having over 50 full -time equivalent
employees) who do not offer health insurance coverage that is “Affordable” and of
“Minimum Value” to full-time employees as defined in the regulation. The City’s practice
is to offer health insurance to all regular and limited-term contract employees and ACA
extends these benefits to temporary employees that are considered full time based on
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Item 5k
hours worked. Full-time under the ACA is defined as an employee who works 30 hours
per week or is expected to average at least 30 hours of work each week for the relevant
measurement period as described in the policy.
On October 1, 2013, the City Council approved Resolution #10461 adopting policy
guidelines to comply with ACA. These policy provisions went into effect for coverage
starting January 1, 2015. Included in that Resolution was adoption of the Rate of Pay
Safe Harbor method1 to determine the affordability of minimum essential coverage that is
offered to the City’s full-time employees. At the same time, the 12-month measurement
period was adopted, which the City uses to determine whether an employee is considered
full time under the ACA.
Pursuant to the Affordable Care Act, the City is required to report annually on its offers of
coverage to employees. The City produces and provides a Form 1095-C to each covered
employee and reports the information to both the Internal Revenue Service (“IRS”) and
the California Francise Tax Board via an electronic Form 1094-C.
City staff regularly consult with the law firm Liebert Cassidy Whitmore (“LCW ”) on a variety
of employment law matters and learned that while the ACA has been in place for a number
of years, the IRS has begun increasing its audits and enforcement. This encouraged City
staff to conduct a review of current City practices related to ACA reporting and offers of
coverage under the guidance of LCW. As a result, it was recommended that the City
adopt a policy to formally document its reporting and eligibility practices so it would be
simpler to prove compliance should questions or audits arise. These practices are
outlined in the ACA Reporting and Temporary Employee Eligibility Policy (Attachment B).
Proposed Policy
While minor enhancements to the City’s current procedures were made, the policy largely
serves to formalize the City’s current practices. If the City receives questions in the future
regarding its compliance with ACA guidelines, the policy will help the City more easily
demonstrate its alignment with those requirements. In addition to the new policy, City staff
took the opportunity to clarify other documents used in the process of offering insurance
coverage, such as the language contained in various Memoranda of Understanding with
bargaining groups regarding cash-in-lieu for employees who opt out, as well as the waiver
form that employees who opt out are required to sign annually.
The policy provides an overview of the general requirements of the ACA and the City’s
statement of policy regarding offers of health insurance coverage. The policy lays out how
temporary employees are deemed eligible for coverage, using their hours of service and
a standard measurement period that occurs annually. It also describes different
employment statuses such as newly hired, ongoing, seasonal vs. variable hour, break in
service or on unpaid leave, and how their status impacts their eligibility. The policy also
1 The Rate of Pay Safe Harbor uses an employee's hourly rate or monthly salary to determine if their
health insurance is affordable. To be considered affordable under this safe harbor, an employee's
contribution for self-only coverage must not exceed a percentage set by the IRS each year (9.02% for
2025).
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details the method used to determine affordability under the ACA and how the City
determines the employee’s premium contribution .
Previous Council or Advisory Body Action
On October 1, 2013, the City Council established the City’s intent to comply with the
ACA’s requirements for Employer Shared Responsibility. See Resolution No. 10461.
ENVIRONMENTAL REVIEW
The California Environmental Quality Act (“CEQA”) does not apply to the recommended
action in this report, because the action does not constitute a “Project” under CEQA
Guidelines Sec. 15378.
FISCAL IMPACT
There is no impact from the recommendations included in the report because the new
policy formalizes current practices.
Fiscal Analysis:
Funding
Sources
Total Budget
Available
Current
Funding
Request
Remaining
Balance
Annual
Ongoing
Cost
General Fund $0 $0 $0 $0
State
Federal
Fees
Other:
Total $0 $0 $0 $0
ALTERNATIVES
1. Council could decide not to adopt this policy. The policy demonstrates
compliance with the provisions of the Affordable Care Act and is consistent with the
City’s current practices. Without the policy, the City may be vulnerable to IRS
penalties.
2. Council could decide to modify the City’s practices related to ACA compliance.
Changes to the method of determining eligibility or affordability for minimum essential
coverage would require staff to consult with legal counsel to ensure continued
compliance and determine any fiscal impact to making the change(s).
ATTACHMENTS
A - Draft Resolution Implementing the ACA Reporting and Temporary Employee Eligibility
Policy”
B - Exhibit 1 - Draft ACA Reporting and Temporary Employee Eligibility Policy
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R ______
RESOLUTION NO. _____ (2025 SERIES)
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF SAN LUIS
OBISPO, CALIFORNIA, ADOPTING THE AFFORDABLE CARE ACT
REPORTING AND TEMPORARY EMPLOYEE ELIGIBILITY POLICY
WHEREAS, the City Council adopted Resolution No. 10461 (2013 Series)
establishing the City’s intent to comply with the Affordable Care Act Employers Shared
Responsibility; and
WHEREAS, the City desires to formalize its current practices and best practices
related to the Affordable Care Act compliance in a standalone policy.
NOW, THEREFORE, BE IT RESOLVED by the Council of the City of San Luis
Obispo as follows:
SECTION 1. The City Council hereby adopts the Affordable Care Act Reporting
and Temporary Employee Eligibility Policy, attached as Exhibit 1.
SECTION 2. The City Council hereby delegates authority to the City Manage r to
make future administrative changes to the policy as deemed necessary to remain
compliant with the Affordable Care Act.
Upon motion of Council Member ___________, seconded by Council Member
___________, and on the following roll call vote:
AYES:
NOES:
ABSENT:
The foregoing resolution was adopted this _____ day of _______________ 2025.
___________________________
Mayor Erica A. Stewart
ATTEST: APPROVED AS TO FORM:
______________________ ______________________
Teresa Purrington, City Clerk J. Christine Dietrick, City Attorney
IN WITNESS WHEREOF, I have hereunto set my hand and affixed the official seal of the
City of San Luis Obispo, California, on ______________________.
___________________________
Teresa Purrington, City Clerk
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Revised 04/29/25 Page 1 of 9 Policy Number
ACA Reporting and Temporary
Employee Eligibility Policy
PURPOSE: ................................................................................................................................ 2
SCOPE ...................................................................................................................................... 2
THIS POLICY APPLIES TO ALL CITY OF SAN LUIS OBISPO EMPLOYEES. ........................ 2
COMPLIANCE ........................................................................................................................... 2
STATEMENT OF POLICY: ........................................................................................................ 2
LOOKBACK SAFE HARBOR: .................................................................................................. 3
1. Hours of Service Calculation: ......................................................................................... 3
2. Ongoing Employees: ...................................................................................................... 3
3. Newly Hired Employees ................................................................................................. 4
4. New Variable Hour, New Seasonal, and New Part-Time Employees: ............................. 5
5. New Variable Hour, Part-Time or Seasonal Employee’s Change in Status During Initial
Measurement Period .............................................................................................................. 6
6. Transitioning from New to Ongoing Employee ................................................................ 6
7. Breaks In Service ........................................................................................................... 7
8. Special Unpaid Leave ..................................................................................................... 7
AFFORDABILITY SAFE HARBORS: ........................................................................................ 7
1. Rate of Pay Safe Harbor ................................................................................................ 7
2. Form W-2 Safe Harbor ................................................................................................... 8
3. Federal Poverty Line Safe Harbor .................................................................................. 8
4. Required Premium Contribution:..................................................................................... 8
REVISIONS/UPDATES TO POLICY: ........................................................................................ 9
LEGAL AUTHORITY: ................................................................................................................ 9
APPROVAL AUTHORITY: ........................................................................................................ 9
QUESTIONS:............................................................................................................................. 9
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PURPOSE:
To formally document the City’s practices related to “Lookback Measurement Method Safe
Harbor” (hereinafter referred to as the “Lookback Safe Harbor”) under the Patient Protection and
Affordable Care Act (“ACA”) for purposes of (1) identifying “full-time” employees for the IRS
reporting requirements related to the Employer Mandate as to all employees, and (2) determining
eligibility for an offer of coverage for Temporary Employees, also known as Supplemental
Employees, unless otherwise provided by an alternative policy or written agreement.
SCOPE
This policy applies to all City of San Luis Obispo employees.
COMPLIANCE
The City of San Luis Obispo (“City”) is considered a “large employer” for the purposes of the
Shared Responsibility Provisions (26 United States Code Section 4980H) of the ACA. The City is
also considered a “large employer” for the purposes of 26 United States Code Section 6056 and,
therefore, is subject to the reporting requirements referenced therein.
The Internal Revenue Service (“IRS”) may assess a penalty on the City if (1) it fails to offer
“substantially all” of its full-time employees (and their dependents) the opportunity to enroll in
minimum essential coverage or offers coverage to “substantially all” of its f ull-time employees
(and their dependents), but that coverage is either “unaffordable” or does not provide “minimum
value” and (2) any full-time employee receives a subsidy for coverage through the exchange
(“Employer Mandate”).
The IRS requires the City to report the identity of, number of, and coverage offered to, full-time
employees, subject to certain potential alternative reporting.
Per the requirements of the ACA, the City is required to establish and maintain a process f or
determining when employees are eligible for health insurance.
STATEMENT OF POLICY:
The City offers health insurance coverage to all full-time employees and those employees who
are regular part-time (defined as working 30 hours a week or more) under applicable collective
bargaining agreements or resolutions.
Regular or contract full-time and part-time employees are offered health insurance in compliance
with CalPERS rules, which state that an eligible employee may enroll in coverage within the first
60 days of employment, and coverage is effective the first of the month following the enrollment
election date.
Nothing in this policy shall be construed as the City’s determination for eligibility for health
coverage as to any represented employee, any Unrepresented Confidential or Unrepresented
Management employee, or employee under contract with the City, including City Council
members. Qualification for health coverage for such employees shall continue to be governed by
the terms of any applicable Memorandum of Understanding or other applicable Resolution or
contract.
This policy also establishes the Affordability Safe Harbors to determine affordability of coverage
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offered, if any, for the Employer Mandate and reporting requirements.
LOOKBACK SAFE HARBOR:
The City adopts the Lookback Safe Harbor in order to determine the Hours of Service of all
temporary employees. Hours of Service are measured during the specified measurement period.
If the employee averages 30 Hours of Service per week over the course of the specified
measurement period, the City will report to the IRS the employee’s status as full-time under the
ACA for months during the stability period associated with that measurement period, subject to
the following rules. If a Temporary Employee averages 30 Hours of Service per week over the
course of the specified measurement period, the City will provide an offer of health coverage for
the stability period associated with the measurement period.
1. Hours of Service Calculation: “Hours of Service” means each hour for which an
employee is paid, or entitled to payment for the performance of duties for the City and
each hour for which an employee is paid or entitled to payment for a period of time during
which no duties are performed due to vacation, holiday, illness, incapacity (including
disability), layoff, jury duty, military duty or leave of absence.
For Hourly Employees: The City will calculate actual Hours of Service from records of
hours worked and hours for which payment is made or due.
Bona fide Volunteer: The City is not required to determine Hours of Service for a bona fide
volunteer. A bona fide volunteer is an individual whose only compensation from the City
is in the form of (a) reimbursement (or reasonable allowance) for reasonable expenses
incurred in the performance of volunteer service; or (b) reasonable benefits and nominal
fees, customarily paid by similar entities in connection with the performance of services
by volunteers.
2. Ongoing Employees: An ongoing employee is an employee who has been employed for
at least one complete Standard Measurement Period. The City establishes the Lookback
Safe Harbor with regard to all ongoing employees as follows:
Standard Measurement Period: November 2 through November 1
The Standard Measurement Period is the span of months during which an employee’s
hours of service are measured to determine whether that employee qualifies as full-time.
Administrative Period: November 2 through December 31
The Administrative Period is the period of time between the Standard Measurement Period
and the Stability Period, where the City makes the offer of coverage to eligible employees
and completes any applicable enrollments.
Stability Period: January 1 through December 31
The Stability Period is the time period that employers must offer health coverage to all
employees who were determined to be full-time during the standard measurement period.
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The City will use these periods for reporting purposes and to determine whether a Temporary
Employee is eligible for coverage. Temporary Employees who average at least 30 hours per week
during the Standard Measurement Period are treated as full-time employees for purposes of
eligibility for health insurance during the entire Stability Period. If an ongoing employee’s
employment status changes (from full-time to less than full-time or vice versa) before the end of
a Stability Period, the change in status will not affect the classification of that employee’s status
for the remaining portion of the Stability Period.
Monthly Lookback reports will continue to be run to ensure employees are being reviewed for
eligibility.
The City will not consider these specific time periods when deciding if an employee, whether they
are represented, unrepresented management, unrepresented confidential, or under contract,
qualifies for a benefits offer. This determination is outlined in the collective bargaining agreement,
resolution, or relevant contract, not based on these specific periods.
3. Newly Hired Employees: For employees who are new to employment with the City and
who have not been employed for at least one complete Standard Measurement Period,
the City will determine which of the following applies:
a. New Seasonal Employees: An employee who is hired into a position for which the
customary annual employment is six months or less is considered a seasonal
employee. The City will measure a new seasonal employee’s Hours of Service using
the Initial Measurement Period indicated in Section 5.
b. New Non-Seasonal Employees: On the start date of a new non-seasonal employee,
the City will determine (based on the facts and circumstances at the employee’s start
date and after analyzing the position pursuant to the Supplemental Employee Policy),
whether the employee is reasonably expected to be a full-time employee. The City will
look at the following factors to determine whether an employee is reasonably expected
to be a full-time employee:
Whether the employee is replacing a full-time employee;
Extent to which Hours of Service of ongoing employees in the same or
comparable positions have varied above and below an average of 30 Hours
of Service per week during recent measurement periods;
Whether the job was advertised or communicated to the employee as
requiring an average of 30 or more Hours of Service per week;
Whether the job was documented (through a contract or job description) as
requiring an average of 30 or more Hours of Service per week.
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No single factor is determinative.
c. New Full-Time Employees: If the City determines (pursuant to Section 3.b.) that the
employee is reasonably expected to average at least 30 Hours of Service per week,
the City will offer coverage within 60 days of the Temporary Employee’s start date.
d. New Part-Time Employee: If the City determines (pursuant to Section 3.b.) that the
employee is reasonably expected to average less than 30 Hours of Service per week
during the Initial Measurement Period, then the employee will be a part-time employee.
The City will measure a new part-time employee’s Hours of Service using the Initial
Measurement Period indicated in Section 5.
e. New Variable Hour Employees: If the City cannot determine (pursuant to Section 3.b.)
whether the employee is reasonably expected to be employed on average at least 30
Hours of Service per week during the Initial Measurement Period because the
employee’s hours are variable or uncertain, then the employee will be a variable hour
employee. The City may not take into account the likelihood that the employee may
terminate employment before the end of the Initial Measurement Period. The City will
measure a new variable hour employee’s Hours of Service using the Initial
Measurement Period indicated in Section 5.
4. New Variable Hour, New Seasonal, and New Part-Time Employees: The City
establishes the following periods for new variable hour, new seasonal, and new part-time
employees:
Initial Measurement Period
The City will measure the hours of service for the employee for the first 12 months of their
employment, beginning on the first of the month following the hire date (unless the
employee starts on the first day of the month, in which case the Initial Measurement Period
begins on the start date).
Initial Administrative Period
The City will designate the 60 days following the Initial Measurement Period as the Initial
Administrative Period.
Initial Stability Period
The City designates the 12 months following the end of the Initial Administrative Period,
as the Initial Stability Period.
During the Initial Measurement Period, the City will measure the Hours of Service
completed by the new variable hour, seasonal, or part-time employee and determine
whether the employee completed an average of 30 Hours of Service per week or more. If
the employee averages 30 or more Hours of Service per week during the Initial
Measurement Period, they will be offered enrollment in health insurance for the Initial
Stability Period.
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However, if the new variable hour, part-time or seasonal employee does not measure as
a full-time employee during the initial measurement period, then the City will use the
standard stability period that is associated with the overlapping standard measurement
period to transition the employe to an Ongoing Employee status, which will determine
eligibility for coverage.
5. New Variable Hour, Part-Time or Seasonal Employee’s Change in Status During
Initial Measurement Period:
If a new variable hour, part-time, or seasonal employee’s position changes during the Initial
Measurement Period, and had the employee started their employment in that new position, the
City would have reasonably expected that new employee to average at least 30 Hours of Service
per week, then for purposes of identifying a full-time employee for reporting purposes only, an
employee will be considered a full-time employee on the earlier of: (1) the first day of the fourth
full calendar month following the change in employment status; or (2) the first day of the first
month following the end of that employee’s Initial Measurement Period if the employee averaged
30 or more Hours of Service per week during the Initial Measurement Period.
If a new Temporary variable hour, part-time, or seasonal employee’s position changes during the
Initial Measurement Period, and had the employee started his or her employment in that new
position, the City would have reasonably expected that employee to average at least 30 Hours of
Service per week, then for purposes of offering health coverage to Temporary employees, the
City will offer health coverage to the employee on the first day of the month following the change
in status to full-time.
6. Transitioning from New to Ongoing Employee:
The City will measure the Hours of Service of a new variable hour, seasonal, or part-time
employee during the first complete Standard Measurement Period for which they are employed.
This means that a new variable hour, seasonal, or part-time employee’s Hours of Service will be
measured both under an Initial Measurement Period and, at the same time, be measured under
the overlapping Standard Measurement Period.
a. If an employee’s Hours of Service measure as full-time during the Initial Measurement
Period, the employee will retain full-time status for the entire associated Stability Period
(even if the employee does not qualify as full-time during the Standard Measurement
Period).
b. If an employee’s Hours of Service do not measure as full-time during the Initial
Measurement Period, but do measure as full-time during the Standard Measurement
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Period, the employee must be treated as full-time during the Stability Period associated
with the Standard Measurement Period (even if that Stability Period starts before the end
of the Stability Period associated with the Initial Measurement Period).
7. Breaks In Service:
When an employee experiences a break in service without providing at least one Hour of Service,
the employee will retain the status the employee had previously with respect to any Stability
Period, except that an employee will be treated as a new employee if:
a. the employee resumes employment after a period of at least 13 consecutive weeks
with less than an Hour of Service; or
b. the employee’s period of no service (measured in weeks) is at least four
consecutive weeks long and exceeds the number of weeks of that employee’s
period of employment immediately preceding the period of no service (after
application of averaging Special Unpaid Leave as set forth in Section 9).
8. Special Unpaid Leave:
Special Unpaid Leave is defined only as unpaid leave under the Family and Medical Leave Act of
1993, unpaid leave under the Uniformed Services Employment and Reemployment Rights Act of
1994, or unpaid leave on account of jury duty. When an employee takes Special Unpaid Leave,
the City will determine the weekly average of Hours of Service by the employee for that portion of
the measurement period that is not part of the Special Unpaid Leave (“Average Weekly Hours of
Service”). The City will then determine, on a consistent basis, the average Hours of Service for
the entire measurement period using one of the following two methods:
a. exclude the period of Special Unpaid Leave and apply the Average Weekly Hours of
Service over the entire measurement period; or
b. credit the Average Weekly Hours of Service to the period of Special Unpaid Leave.
AFFORDABILITY SAFE HARBORS:
For reporting purposes only, the City intends to apply the Rate of Pay Safe Harbor to determine
the affordability of the minimum essential coverage that it offers its full-time employees. The City
in its sole discretion may also apply the Form W -2 Safe Harbor or Federal Poverty Line Safe
Harbor. These affordability safe harbors will be applied on a uniform and consistent basis for all
employees in a reasonable category. The 9.02 percent determination under the affordability safe
harbors applies for calendar year 2025 and shall be adjusted to reflect any indexing adjustments
made pursuant to 26 U.S.C. § 36B(c)(2)(C)(iv) (“Applicable Percentage Rate”).
1. Rate of Pay Safe Harbor
a. The City measures whether the employee’s Required Premium Contribution (as
defined in Section 4 below) for the calendar month toward the lowest cost self-only
coverage that provides minimum value exceeds the Applicable Percentage Rate
of the employee’s monthly wage.
b. For hourly employees, the monthly wage is equal to 130 hours multiplied by the
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employee’s hourly rate of pay as of the first day of the coverage period or the
employee’s lowest hourly rate of pay during the calendar month, whichever is
lower.
c. For salaried employees, the monthly wage is the monthly salary as of the first day
of the coverage period. However, if the monthly salary is reduced, including due
to a reduction in work hours, the safe harbor is not available. If the rate of pay
increases during the year, the City will use the lowest rate of pay for the year in the
calculation.
d. The coverage offered by the City will be deemed affordable if the employee’s
monthly Required Premium Contribution is equal to or less than the Applicable
Percentage Rate of the employee’s monthly wage.
2. Form W-2 Safe Harbor
a. The City measures whether the employee’s Required Premium Contribution for
the full calendar year for the lowest cost self-only coverage that provides minimum
value exceeds an amount equal to the Applicable Percentage Rate of the
employee’s Form W -2 wages (as reported in Box 1) for the calendar year in which
coverage is offered.
b. For an employee who is not offered coverage for an entire calendar year, the City
must adjust that employee’s Form W -2 wages to reflect the period for which
coverage was offered. To adjust wages, the Form W -2 wages are multiplied by a
fraction equal to the number of calendar months the City offered coverage over the
number of calendar months in the period of employment during the calendar year.
c. The coverage offered by the City will be deemed affordable if the employee’s
annual Required Premium Contribution is equal to or less than the Applicable
Percentage Rate of the employee’s Form W -2 wages as reported in Box 1 (or as
adjusted, for an employee who is not offered coverage or an entire calendar year).
3. Federal Poverty Line Safe Harbor
a. The City measures whether the employee’s Required Premium Contribution for
the calendar month for the lowest cost self -only coverage that provides minimum
value exceeds the Applicable Percentage Rate of the Federal Poverty Line (“FPL”)
for a single individual for the applicable calendar year, divided by twelve.
b. The City will use the FPL in effect within six months before the first day of the plan
year.
c. The coverage offered by the City will be deemed affordable if the employee’s
Required Premium Contribution is equal to or less than the Applicable Percentage
Rate of the monthly FPL for a single individual for the applicable calendar year.
4. Required Premium Contribution: The City will calculate the employee’s Required Premium
Contribution as follows:
a. Identify the premium cost for the lowest cost plan offered to the employee.
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b. Subtract any employer contribution that qualifies as a Health Flex Contribution.
A Health Flex Contribution is an employer contribution that cannot be cashed
out by the employee and cannot be applied to benefits other than health
insurance coverage.
REVISIONS/UPDATES TO POLICY:
This Policy is subject to change as regulations and guidance are issued relating to the ACA.
LEGAL AUTHORITY:
Title 26 United States Code section 4980H, (Internal Revenue Code);
Shared Responsibility for Employers Regarding Health Coverage,
26 CFR Parts 1, 54 and 301, 79 Fed. Reg. 8544 (Feb. 12, 2014);
Title 26 United States Code section 6056, (Internal Revenue Code);
Information Reporting by Applicable Large Employers on Health Insurance Coverage Offered
Under Employer Sponsored Plans,
26 CFR Parts 301 and 602, 79 Fed. Reg. 13231 (March 10, 2014).
APPROVAL AUTHORITY: The City Council has delegated authority to the City Manager for
future updates to this policy.
Responsible Department: Human Resources Department
Approved By: City Council
Date Adopted:
Date Revised: N/A
QUESTIONS:
For questions regarding this policy or to discuss a particular situation, please contact the Human
Resources Department at (805) 781-7250.
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