College Adjunct Faculty Input by Midnight March 18, 2013, for IRS and Treasury Hours of Work Guidelines

Here is some time-sensitive and important information regarding providing the IRS and the Treasury department with your input about faculty preparation and additional work hours: Due by midnight, Monday, March 18, 2013:

"The IRS and the Treasury department are considering using a conversion rate for adjunct faculty that would count one credit as three hours for purposes of calculating hours/week of work. (The Carnegie conversion). SEIU members feel that this conversion rate grossly underestimates the amount of work that is actually done, and is not an accurate method for measuring the real work of contingent faculty."
http://www.regulations.gov/#!submitComment;D=IRS-2013-0001-0012

From the Seattle area:
Please read the message below my reply and respond by March 18 (Monday).

	It appears the proposed rule is only accounting for actual classroom contact hours per credit. I, and several other adjunct faculty members from the community colleges, worked with the Washington state Employment Security Department over a period of 2-3 years a decade ago to develop a scaling formula that accounts for the outside prep hours (prep, grading, meeting with students, course design) based on the classroom contact hours reported to the department for determining eligibility for unemployment benefits during summer breaks and other periods of non-employment. I have made reference to these rules in my comments to the IRS as a possible model for the feds to follow in determining an accurate accounting of the actual number of hours worked per specified number of academic credits taught. You might mention the same rules in the Revised Code of Washington (RCW). Dana Rush From SEIU Local 925 As you all probably already know, new federal rules will require employers to provide healthcare coverage to all workers working over 30 hours/week. Contingent faculty, unlike many other workers don’t punch a clock, so there is no easy metric for how many hours a professor works a week. The IRS and the Treasury department are considering using a conversion rate for adjunct faculty that would count one credit as three hours for purposes of calculating hours/week of work. (The Carnegie conversion). SEIU members feel that this conversion rate grossly underestimates the amount of work that is actually done, and is not an accurate method for measuring the real work of contingent faculty. The period for comment to the IRS closes Monday, March 18, and SEIU’s experience is that in the IRS’s eyes, quantity matters. SEIU members are being urged to contact the IRS today to tell the IRS NOT to adopt the three hours/credit conversion. I’m pasting a copy of the email blast that is going out to all 2.2 million SEIU members. Even though you don’t belong to SEIU yet, I am hoping you will take the opportunity to urge the IRS not to undervalue your time and work. How those hours are counted could substantially impact adjunct faculty access to affordable healthcare. For adjunct professors, the work doesn't stop at the classroom door, but the pay and benefits often do. Contract faculty, who make up 70% of instructional faculty nationwide, spend many hours outside of the classroom preparing courses, supporting and assessing student performance, and designing curriculums. Right now, the Treasury Department and the IRS are asking for guidance on how to determine adjunct faculty hours as a way of assessing an employer's responsibility for coverage under the Affordable Care Act (ACA). The standard the Treasury Department and the IRS are considering - a three hour per course credit standard - grossly underestimates the time adjuncts spend working outside the classroom. Click here to submit your comments to the IRS now to let them know adjunct working hours should be assessed in a way that accurately reflects their true workload. Treasury Department and the IRS need to hear directly from adjunct faculty about the size and breadth of the workloads outside the classroom which are critical to providing the quality instruction and support students deserve. No singular standard can accurately and fairly calculate the hours for adjunct faculty. Too many factors influence the actual hours required to teach the same number of credit hours. The Treasury Department and the IRS should establish a minimal standard, and instruct higher education institutions to adjust that standard when specific circumstances increase the workload of adjunct faculty. All comments must be submitted by midnight on March 18th. Click here to submit yours now.