Hourly Employees

Benefits Eligibility

The Washington State Health Care Authority (HCA) has provided new guidelines for hourly employee benefits eligibility. Employees who work 480 hours or more over a consecutive 6 month period become benefit eligible at the beginning of month 7.

An employee must report a minimum of eight hours in month 7 to receive the insurance benefits. After establishing eligibility, if an employee does not work a minimum of eight hours in any month, the employee will lose benefit eligibility and must reestablish eligibility by working a minimum of 480 hours or more over a new 6 consecutive month period.

These new guidelines become effective January 2010, but the period we use to calculate 480 hours is six months PRIOR to January 2010. Any employee who has worked 480 hours over the previous six months on January 2010, will be eligible for benefits.

As a reminder, the employer contribution for insurance premiums for non-student temporary hourly employees is funded by their employing department, and not through central funding.

We have also provided information that summarizes the three main rules for monitoring hours for hourly employees.

Hourly Insurance Benefit Eligibility Q&A

Why did the Health Care Authority (HCA) decide to apply different insurance eligibility requirements to nonpermanent employees?

Due to ongoing litigation involving part-time employees, the Health Care Authority is requiring that all employing agencies and higher education institutions average an employee’s work hours over a 6 month period for nonpermanent employees, to determine if the employee has worked half-time or more during that period.

What are “nonpermanent employees?”

WAC 182-12-115 (2) defines nonpermanent as “…those who work at least half-time and are expected to be employed for no more than six months. These employees are eligible for benefits on the first day of the seventh month of half-time or more employment. Insurance coverage begins on the first day of the seventh month following the date of employment.”

How will eligibility be calculated?

Employees who work 480 hours or more over a consecutive 6 month period become benefit eligible at the beginning of month 7. Note: An employee must report a minimum of eight hours in
month 7 to receive the insurance benefits. After establishing eligibility, if an employee does not
work a minimum of eight hours in any month, the employee will lose insurance eligibility and must reestablish eligibility by working a minimum of 480 hours or more over a new look forward six consecutive month period.

How was eligibility determined prior to this change?

Highline had determined eligibility for hourly employees by looking at each month individually, and determining what the half-time or more hours were for that month. If an employee worked half-time or more of actual hours in a month, for six consecutive months, then they were determined to be benefits eligible as of the seventh month. Under the new rules, we will no longer be looking at actual hours on a month by month basis, but instead looking at an entire six month period, and looking for employment of 480 hours or more.

Will Human Resources notify the department prior to the employee becoming benefit eligible?

Because Human Resources can only determine benefit eligibility based on the hours the employee has already worked, we are only able to notify employees and departments after becoming benefit eligible.

How can I monitor the 480 hours over the consecutive 6 month period.

We recommend you follow the same process you are currently using to monitor time worked by your hourly employees. Many supervisors have developed spreadsheets or retain timesheets to track hours.

Unfortunately, our payroll system which is now well over 20 years old was not designed for this type of monitoring.

How was it determined that 480 hours over a six month period would be the eligibility criteria?

480 over six months equals 6 months at 80 hours a month, if each month was worked an equal number of hours. However, since we no longer look at each month separately, the 480 hours can be reached in a multitude of ways. For example, if an employee worked the following, they would meet the averaging criteria of half time or more:

• 1st month = 168 hours
• 2nd month = 152 hours
• 3rd month = 8 hours
• 4th month = 8 hours
• 5th month = 96 hours
• 6th month = 60 hours
• Total Hours = 492 > 480 hours over a 6 month period, and therefore eligible for benefits as of month
  seven.

If I have an employee who is nearing the 480 hours, can I stop working them to avoid having the employee become benefit eligible?

No, RCW 49.44.160 prohibits public employers from taking action to avoid providing or continuing to provide employment-based benefits to which employees are entitled. Decision to discontinue employment must be based on a legitimate business need.

Who is responsible for paying the cost of medical coverage once an employee becomes benefit eligible?

The employing department is responsible for the employer contributions. For fiscal year 2009, the
employer contributions are $745.00. If the employee elects to waive coverage, the employing
department is still required to pay the entire monthly cost to HCA. If an employee is employed by more than one department the employer contributions will be prorated.

How are the employee’s insurance premiums determined?

The employee premiums will be determined based upon selection of the medical carrier and optional benefits. Refer to Washington State Health Care Authority for additional information regarding employee paid premiums.

Do overtime hours count toward the 480 hours?

Yes, the hours actually worked are counted (e.g. worked 1 hour overtime, paid for 1.5 hours).
The 1 hour actually worked will be counted.