The concepts of “hours of service” and “full time” loom large in the Affordable Care Act’s “employer shared responsibility” mandate. An employee who works 30 “hours of service” per week is considered to be “full time” under the mandate. Whether an employer is subject to the employer mandate at all depends on the number of its “full time” and “full time equivalent” employees. And whether the employer might be liable for a penalty depends on whether it makes an ACA-compliant offer of coverage to each of its “full time” employees.

But what happens when “hours of service” are not easily captured as is the case with adjunct faculty members?

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