Q: How should we be tracking the hours for coaches? Do we have to include substitute teachers as part time employees? We are thinking of hiring an intern and paying a stipend. Do we have to offer the intern health insurance? Do we count Summer Camp employees? How do we keep track of Part-time employee hours?
A: I get many questions on counting part-time employees, especially hard to track employees. The ACA requires that you count all part-time employee’s hours as these hours are included in your Full Time Equivalent Employee number.
Let’s look at some of the part-time employees who are hard to track.
Coaches
Coaches are hired for the seasons during which they coach, and maybe for a summer sport camp. What hours do you count? You would count the hours they are actually working: at games, occasions during which they directly supervision of the athletes (including rides to away games), and at practice.
You need a reporting system to document the hours they work. This documentation could be a sign in/out sheet, a self-reporting time sheet, or the head coach reporting their hours. If the position requires preparation time outside of actual work time, you would have to include that preparation time. Discussion with the athletic director or head coach will determine what method works best for your school. You need to be consistent with all your coaches for documenting time.
Substitute Teachers
Substitute Teachers' hours are included in your monthly count. Substitutes who are called in for the day would not have any preparation time to document. Long term substitute teachers will require preparation time if they work less than 30 hours per week. If they are hired to work full time for more than 90 days, you will have to offer them health insurance.
Interns
Paid interns that work more than 30 hours per week are full-time employees and must be offered health insurance after your waiting period. The Intern may not elect to enroll in your insurance if they are under 26, however, as he/she would be covered by one of his/her parent’s insurance.
Summer Camp Employees
Summer camp employees may be considered seasonal employees if they are hired for six months or less and that period is the same each calendar year. You have to count them as employees in your monthly employee count but you do not have to offer them health insurance even if they are full-time. If the seasonal employees increase your employee count above 49 FTE employees, it does not make you a large employer if the number decreases back below 50 in September.
With this information you should be better prepared to track those employees who do not work regularly scheduled hours. Remember to be consistent in the method you use and to maintain records of your employee counts.
Curious about your school's health care policies and the reform's changes? Ask ISM’s Health Care Reform Expert a question. We respect your privacy. You can also view ISM’s health care solutions.
