Proposed USPS Changes to Support Affordable Care Act Reporting 06/06/2013

30 Hour Rule Reporting Disclaimer – the following information details our current understanding of the “Employer Shared Responsibility Provisions” included in the “Affordable Care Act” and our planned software updates to assist districts in complying with them. This should not be considered legal guidance and is subject to change as our understanding of the law and its implications evolve.

30 Hour Rule The piece of law commonly referred to as “the 30 hour rule” states that any employee who works an average of 30 hours per week (or 130 hours in a month) is considered full time under the “Affordable Care Act” Any “large employer” (defined as having 50 or more full time employees) must offer these full time employees a minimum level of affordable health insurance coverage (defined as no more than 9.5% of employee’s income) or be subject to a “Shared Responsibility Payment”

30 Hour Rule Penalties There are two potential employer penalties – Penalty 1 – If the employer does not offer minimum essential coverage to 95% of full time employees (and dependent children) and a full time employee applies for and receives a subsidy Penalty is $2,000 x (num. of full time employees – 30) – Penalty 2 – If minimum coverage is offered, but one full time employee gets a subsidy because coverage is not affordable (< 9.5% of income) Penalty is $3,000 x num. full time employees receiving subsidy (not to exceed penalty 1)

30 Hour Rule This law goes into effect January 1 st, 2014 Information collected in 2013 will be used to determine full time status Under the law there are several different ways full time status can be determined

30 Hour Rule Annually (snapshot) Monthly (snapshot) Optional Safe Harbor Alternative – Measurement period of 3 to 12 months to determine status – Administration period of 0 – 90 days – Stability Period (where determined status applies) For employees determined to be full time must be at least 6 months and no shorter than the measurement period For those determined not to be full time can be no longer than the measurement period

30 Hour Rule Transition relief will be provided in 2013 For administrative convenience a shorter measurement period (no less than 6 months) can be used with a longer (12 month) stability period Measurement period can be begin no later than 7/1/13

USPS Proposed Updates In USPS we believe we can help districts with this reporting using the existing “retire hours” functionality This allows hours to be tracked on a per pay basis for any employee in USPS (regardless of retirement system) Adjustments can also be made via ATDSCN using the AD RH transaction type and category

USPS Proposed Updates Once this information is tracked we can then use it for reporting We plan to support the safe harbor method for averaging both weekly and monthly hours We will create a report that allows the district to enter in a beginning and ending date along with several other selection options – Pay group – Exclude by deduction code (allows filtering those with medical insurance) – Specific employee selection – Etc.

USPS Proposed Updates The dates entered will then be compared to the beginning and ending dates in check history to determine which historical pay records apply for hours reporting These same dates will be used to accumulate any applicable ATDSCN adjustments Each employee’s hours will be totaled and divided by the applicable number of weeks or months to provide an average

USPS Proposed Updates Both a summary report and CSV file will be provided when the report is executed We believe this will help facilitate the reporting necessary for the ACA provisions. However, manual review / adjustments will most likely still be necessary for some employees Initial development efforts have begun and this report is scheduled to be included in the September 2013 USPS release