The AFT plans to comment again, urging Treasury to stay true to the spirit of the Affordable Care Act, which envisioned widespread access to affordable health coverage. Our comments will argue that:
- Federal regulators should not allow the law to be used as cover for bad employer behavior. The law should not be used improperly to reduce faculty workload, and Treasury should clarify that this was not the intent of the law or regulations.
- Colleges and universities must not be permitted to reduce contingent faculty course loads and shirk the responsibility of providing health coverage under the guise of complying with the ACA, which was intended to lead to more healthcare coverage, not less.
- Contingent faculty members must be treated as professionals.
We would like to see guidance from federal regulators that incorporates these principles either in the rules or in other guidance directed at institutions of higher education.
Now it’s your turn: How to submit comments
Our case will be stronger if Treasury Department receives significant comments. To that end, we encourage individuals and local unions to submit comments on this issue. You are welcome to incorporate ideas from the paragraph above or our previous comments, or craft your own letter. Because of the diversity of situations on different campuses, it would be helpful for Treasury to receive comments from many different locals and affiliates.
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