[T]he Treasury Department and the IRS have determined that, until further guidance is issued, one (but not the only) method that is reasonable for this purpose would credit an adjunct faculty member of an institution of higher education with (a) 2 1/4 hours of service (representing a combination of teaching or classroom time and time performing related tasks such as class preparation and grading of examinations or papers) per week for each hour of teaching or classroom time (in other words, in addition to crediting an hour of service for each hour teaching in the classroom, this method would credit an additional 1 1/4 hours for activities such as class preparation and grading) and, separately, (b) an hour of service per week for each additional hour outside of the classroom the faculty member spends performing duties they are required to perform (such as required office hours or required attendance at faculty meetings).24

Three timeframes are involved in tracking adjunct hours of service: the stability period, the administrative period, and the measurement period.

• The current academic year corresponds to the stability period. In the stability period, the employee's benefit status, which had been previously established for their position, remains stable, regardless of fluctuations in their hours worked. The stability period is generally 10 or 11 months.
• Following the stability period is an administrative period of 1 or 2 months. During the administrative period, the past workload of each adjunct faculty member is measured to determine a benefit status for the subsequent stability period, which follows the administrative period.

23 https://www.federalregister.gov/d/2014-03082/p-72

24 https://www.federalregister.gov/d/2014-03082/p-77

• The measurement period is the most recently completed stability period used during the administrative period to calculate the average weekly adjunct hours of service.

Once per year in the administrative period, the average weekly hours of service in the measurement period are calculated for each adjunct using a “reasonable method.” The university will use the “look-back measurement method.” Per the Federal Register,

The proposed regulations provide a method, referred to as the look-back measurement method, under which employers may determine the status of an employee as a full-time employee during a future period (referred to as the stability period) based upon the hours of service of the employee in a prior period (referred to as the measurement period).25

In the administrative period, the Office of Human Resources will evaluate adjunct hours of service during the measurement period to determine the appropriate actions to take for benefits administration in the stability period. Any part-time faculty employee (i.e., adjunct faculty member) averaging 30 or more hours of service during the measurement period will be contacted by Human Resources to review health insurance coverage options for the subsequent stability period.

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