TOPIC: ACA Academic Interns
QUESTION:
Is an employer required to offer ACA-qualifying minimum essential coverage for the benefit of its student interns?
ANSWER:
ACA provisions permit an employer to forego an offer of minimum essential coverage in the instance of a bona fide academic intern because work-study hours do not need to be considered as to other hours of service
An “academic intern” is defined as an individual who is currently enrolled, and receiving academic credit, in a course of study. Furthermore, such individual must be either:
- Receiving academic credit in exchange for the employment services provided to the employer; or,
- Receiving federal or state work study grant dollars in exchange for the employment services provided to the employer.
Alternatively, a “student worker” is an individual who, while employed by an employer, is also enrolled in an academic course of studies; however, this individual is not receiving academic credit or federal or state work study grant dollars in connection with the employment services provided to such employer.
A bona fide academic intern is distinguishable from a student worker, in that, in the instance of a student worker, the employer MAY NOT forego an offer of ACA-qualifying minimum essential coverage in the instance of a full-time student worker.
ACTION:
Employers should assess all interns to distinguish between student workers and bona fide academic interns, assuring that they make ACA-qualifying offers of minimum essential coverage to their full-time student workers. Further, employers should maintain adequate documentation and records demonstrating their treatment of bona fide academic interns for coverage purposes.
DETAILS:
For more information, contact the Baldwin Regulatory Compliance Collaborative.
For more information
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