ACA Impact on L&S Student Hourly and TE Employees

ACA Hour Limit Requirements

UW–System is considered a single employer under ACA. Employees working across multiple UW jobs must be monitored for combined hours.

To avoid ACA penalties:

• SH and TE employees must not average more than 29.75 hours per week over a rolling 90-day period.
• This applies across all positions held within UW–System, not just within one department.

Key Considerations

• The 90-day measurement period is rolling, not fixed.
• Employees exceeding this threshold may become benefits-eligible under ACA, creating compliance risks.

Hiring and Scheduling Guidance

1. Evaluate Duration of Employment

When hiring SH or TE employees:

• Less than 90 days
• May exceed 29.75 hours/week if the assignment clearly ends within 90 days.
• An accurate end date must be entered at the time of hire.
• 90 days or more
• Must be scheduled to average no more than 29.75 hours/week for the full appointment.

2. If Workload Requires 30+ Hours/Week (for 90+ Days)

Consider the following options:

• Split workload across multiple SH or TE employees
• Hire into a benefits-eligible position (e.g., University Staff Fixed-Term, Project Assistant) if the work is ongoing (typically 1 year or more)
• Request a Seasonal Exemption (see below)

Seasonal Exemptions (ACA)

Definition of Seasonal Employment

A position may qualify as seasonal if:

• The customary annual employment period is six months or less, and
• The work occurs at approximately the same time each year (e.g., summer or winter), and
• The job cannot be performed at another time of year due to the nature of the work (not due to business need alone)

Seasonal employees are not eligible for ACA benefits, allowing additional flexibility in scheduling.

Requesting a Seasonal Exemption

Departments must complete the Seasonal Exemption Form which includes:

• Job duties
• Dates of seasonal employment
• Justification explaining why the work is inherently seasonal

For SH – submit the form to Shanae Doerr

Seasonal Student Hourly (SH) – 40 Hours/Week Policy

Key Rules

1. Seasonal SH Positions

• SH roles may be designated as seasonal if they meet criteria and are approved.
• Requirements include:
  • Start and end dates entered in Workday
  • Completion of a Seasonal Exemption Form
• All seasonal roles must be formally approved and tracked

2. Hour Limits and Exceptions

Important Notes:

• The seasonal job does not need to be within L&S—any UW seasonal SH job qualifies.
• The 40-hour allowance applies only while the seasonal role is active.

3. Multiple Job Scenarios

• SH employees may hold multiple jobs simultaneously (SH, TA, PA, etc.)
• If at least one SH job is seasonal, the employee:
  • May work up to 40 hours/week across all jobs combined
• If no SH job is seasonal, the employee:
  • Is limited to 30 hours/week total

Examples

✅ Eligible for 40 Hours/Week (Seasonal SH Present)

Example 1

• Job 1: SOAR (Seasonal SH)
• Job 2: Front Desk Attendant (Non-seasonal SH)
  ➡ May work up to 40 hours/week total

Example 2

• Job 1: SOAR (Seasonal SH)
• Job 2: Project Assistantship (50%)
  ➡ May work up to 40 hours/week total

🚫 Limited to 30 Hours/Week (No Seasonal SH)

Example 3

• Job 1: Front Desk Attendant (Non-seasonal SH)
• Job 2: Teaching Assistantship (50%)
  ➡ Limited to 30 hours/week total

Quick Summary

• ACA Rule:
  • Max average = 29.75 hours/week over 90 days (SH & TE)
    
    
• Standard SH Policy:
  
  • Max = 30 hours/week across all jobs
    
    
• Seasonal Exception:
  • ✅ Seasonal SH job → up to 40 hours/week allowed
  • ❌ No seasonal SH job → 30-hour limit applies
    
    
• Seasonal Requirements:
  • Approved designation
  • Workday start/end dates
  • Seasonal Exemption Form
  • Central tracking in Box

Questions

For guidance or approval requests contact the HR representative for the population in question.