The percentage of employees eligible for health care coverage
through SEBB during the 2019-20 school year increased to 77% from 68% eligible in the
2018-19 school year. On average, districts reported paying an estimated 31-44% more per
month under SEBB. Ongoing collection of similar eligibility and cost data would require
changes to OSPI and HCA reporting requirements.
October 2021
Executive Summary
On January 1, 2020, health benefits for eligible school employees were consolidated
under a statewide program called the School Employees Benefits Board (SEBB). Under
SEBB, all school districts pay the same monthly rate per employee for benefits and
offer the same benefit package options. Employees are eligible for health benefits if
they work, or are anticipated to work, 630 hours during the school year.
Prior to SEBB, eligibility for benefits, the packages offered, and district and
employee costs varied by school district and employee position type.
The 2020 Legislature directed JLARC to collect data about school employees, their
position types and hours worked, eligibility for benefits, and school district benefit
costs for the 2018-19 and 2019-20 school years.
For this study, JLARC staff collected data from 212 districts. The reporting
districts reflect the variation in size and geographic distribution across all 295
school districts. This report presents the data for certificatedEmployees with a professional certificate
authorized by the Washington Professional Educator Standards Board.
and classifiedEmployees without a
professional education certificate. employees, position typesPosition types are categories of related
jobs. Section 2 lists position types and examples of job titles.,
and number of hours worked. Because SEBB went into effect in the middle of the 2019-20
school year, data reported under SEBB is for January-August 2020 of the 2019-20 school
year.
Based on data from 212 of 295 districts, the number of full-time employees increased
and the number of part-time employees decreased between the 2018-19 and 2019-20 school
years
The 212 districts reported that 125,990 employees worked during the 2018-19 school
year and 125,135 employees worked during the 2019-20 school year, a one percent
decrease. The number of full-time employees increased by 665. The number of part-time
employees decreased by 1,520.
During the 2019-20 school year, 55% of employees worked full-time. Of the part-time
employees, 54% worked fewer than 630 hours and 46% worked 630 hours or more. The
percentages of full-time and part-time employees were similar during the 2018-19
school year.
The number of employees in most position types remained steady between the two school
years. However, districts reported a 12% reduction in substitute employees during the
2019-20 school year. In March 2020, Washington school buildings closed due to the
COVID-19 pandemic. During the summer of 2020, the Office of the Superintendent of
Public Instruction (OSPI) surveyed districts to learn about staffing changes resulting
from COVID-19. Survey respondents indicated that many substitute employees became
eligible for unemployment due to school closures.
Under SEBB, 77% of school employees were eligible for health benefits, increasing
from 68% eligible during 2018-19
During the 2018-19 school year and under SEBB, the majority of employees eligible for
health benefits worked full-time. The greatest increase in eligibility was for
part-time employees that worked 630 hours or more. In 2018-19, 70% of these part-time
employees were eligible for benefits while under SEBB 97% were eligible. The number of
eligible part-time employees working fewer than 630 hours decreased from 8% to 7%.
Overall, fewer employees (12%) waived medical coverage under SEBB than in 2018-19
(18%).
On average, the 212 districts reported paying an estimated 31-44% more per month for
employee health benefits under SEBB than in 2018-19
JLARC staff asked districts to report the cost for employee health benefits. However,
differences in accounting and payroll systems made it difficult to consistently
compare costs between districts and school years. On average, districts reported
paying an estimated 31-44% more under SEBB than during the 2018-19 school year. JLARC
staff attributed the increased monthly costs to three primary factors:
An increase in the monthly employer rate (the amount districts pay per
employee).
Expanded eligibility.
Districts paying the full employer contribution for part-time employees instead of
a prorated amount.
Recognizing that SEBB would expand coverage, the Legislature funded 2% more
certificated and 25% more classified benefit units under SEBB
The Legislature asked JLARC staff to report the number of certificated and classified
benefit units A term that describes
the number of full-time equivalent school employees funded in the operating budget
multiplied by an additional rate to account for positions filled by more than one
individual eligible for benefits. funded in the biennial operating
budget and the amount of funding allocated from each major program within basic
education.
Under SEBB, the state funded 2% more certificated and 25% more classified benefit
units than during the 2018-19 school year. General apportionment was the largest
source of funding for employee health benefits. Special education was the second
largest.
The state's funding allocation for health benefits under SEBB represented 76% of
school districts' collective reported costs. Funding is not intended to match costs
because each district has discretion in how many staff they hire, how many hours those
staff work, and other factors that affect the cost of health benefits. As a result,
the ratio of funding to spending varied widely across the 212 reporting districts
(ranging from 28% to 240%).
Ongoing collection of similar eligibility and cost data would require changes to
OSPI and HCA reporting requirements
Existing OSPI and Health Care Authority (HCA) data is not detailed enough to answer
the questions addressed in this study on an ongoing basis. OSPI collects employee
information that includes whether an employee is certificated or classified, position
type, and full-time equivalent (FTE). OSPI does not collect data about the number of
hours worked per year or whether the employee is eligible or receiving SEBB benefits,
and some positions are excluded from the reporting requirements.
HCA maintains data about the number of SEBB subscribers and the number who waive
coverage. The data does not include whether the employee is certificated or
classified, their position type, or number of hours worked. HCA also does not collect
information on the number and type of employees who are not eligible for coverage.
Additional information addressing the questions in this study could be collected in
the future by either OSPI or HCA. This would require more work by these agencies and
school districts. Before any new reporting is undertaken, the Legislature should
consider whether this JLARC staff report provides sufficient information or whether
ongoing monitoring is desired.
Legislative Auditor Recommendation
OSPI and HCA should work with House and Senate fiscal staff to determine what
additional data elements might be needed for ongoing data collection. If additional
elements are suggested, OSPI and HCA should each develop a data collection plan and
identify additional resource requirements as applicable.
Preliminary Report: School Employees Benefits Board (SEBB) Coverage
October 2021
Report Details
1. SEBB provides health benefits to school employees
On January 1, 2020, health benefits for eligible school employees
were consolidated under a state program called the School Employees Benefits Board
(SEBB)
The 2017 Legislature began consolidating health benefits for all eligible school
employees under a statewide program called the School Employees Benefits Board (SEBB).
SEBB went into effect on January 1, 2020, partway through the 2019-20 school year. The
Board selects health insurance carriers and determines the scope of coverage for
employees and their dependents. The Health Care Authority (HCA) administers SEBB and
provides staff support to the Board.
SEBB was created to:
Increase transparency of health benefit costs.
Reduce administrative costs for providing employee health benefits by leveraging
purchasing power statewide.
Increase affordability of full-family coverage for all school district
employees.
Create greater equity for employees in different staff positions and between the
costs for full-family and employee-only premiums.
A 2016 JLARC report found that school districts had not met legislative goals for
full-family affordability or equity.
Under SEBB, all school districts pay the same rate and offer the same health care
plans
Before SEBB, each of the state's 295 school districts negotiated health benefits with
local school employee unions. The benefit packages, eligibility criteria, and costs
varied by district and by employee position type.
Under SEBB, eligibility criteria are set in statute: employees are eligible for
health benefits if they work, or are anticipated to work, 630
hours630 hours is 3.5 hours per day during a 180-day
school year. or more during the school year. All school
districts pay the same monthly rate per eligible employee and offer the same benefit
options.
Exhibit 1.1: SEBB changed administration of health care benefits for school
employees
Benefit Characteristics
Before SEBB
Under SEBB
Design and approval of health care plans
Locally negotiated between each school district and bargaining unit (e.g.,
teachers, administrators, teamsters).
SEBB negotiates with carriers and approves plans for the entire state.
Eligibility criteria
Locally negotiated between each school district and bargaining unit.
Set in statute. Every employee who works, or is anticipated to work, at least
630 hours per year is eligible for full benefits.
Employer rate
Locally negotiated between each school district and carriers. Rates varied
between and within school districts depending on an employee's position
type.
HCA recommends a monthly rate through the Governor's budget proposal. The
Legislature sets the actual rate in the biennial operating budget. Fixed cost
per eligible employee.
Waived coverage
Employees could waive coverage.
Districts may not have been responsible for employer contribution for locally
or federally funded employees who waived coverage. Districts were responsible
for employer contribution for all state-funded employees, regardless of
whether they waived coverage.
Employees can waive medical coverage, but not other benefits, such as
dental.
Districts responsible for the employer contribution for all eligible
employees, regardless of how the employees are funded or whether they waive
coverage (rate assumes certain percentage of employees will waive).
Prorated benefits
Districts allowed to prorate employer contribution for part-time
employees.
No employer contributions are prorated.
Full-family coverage
Few districts met the legislative goal of a 3:1 ratio for employee
contributions for family coverage vs. single payer coverage.
All benefit plans under SEBB meet the 3:1 ratio, as required by statute.
Employee contribution
Most districts used a defined contribution model where the district
set an amount to contribute toward employee benefits and the remaining costs
were covered by the employee. The amount of employee contributions varied.
Some employees did not make a contribution due to poolingPer bargaining agreements, state funds
for employees who waived coverage, chose a low-cost plan, or were
ineligible for benefits were pooled together and could be used to pay for
out-of-pocket costs or reduce employees’ contribution for
benefits..
Defined benefit model where the employee contribution is set by SEBB.
All employees statewide make the same contribution for the same plan
selection.
Source: JLARC staff analysis.
SEBB offers medical, dental, vision, and other benefits
Under SEBB, eligible employees can choose from several medical insurance plans, each
with different employee premium costs. The employer (school district) contribution to
the premium is the same for every employee, regardless of the plan selected or the
number of dependents covered. Employers cover 100% of the premiums for dental and
vision plans, basic life insurance, accidental death and dismemberment, and basic
long-term disability.
2020 Legislature directed JLARC to collect data about school employee positions,
hours worked, and eligibility for health benefits
The Legislature directed JLARC staff through ESSB 6189 to report information about
school employees and their eligibility for health benefits during the 2018-19 and
2019-20 school years, including:
Number and types of employees.
Ranges of hours worked by employee position type.
Number eligible for health benefits.
Number waiving coverage.
Amount the district paid for employee health benefits.
Number of certificatedEmployees
with a professional certificate authorized by the Washington Professional
Educator Standards Board. and classifiedEmployees without a professional education
certificate.benefit unitsA term that describes
the number of full-time equivalent school employees funded in the operating
budget multiplied by an additional rate to account for positions filled by more
than one individual eligible for benefits. funded in the state
budget for health benefits.
The Legislature also directed JLARC staff to make recommendations about the ongoing
data collection efforts by the Office of Superintendent of Public Instruction (OSPI)
and the Health Care Authority (HCA), as related to this project. The data elements
needed to answer the current study questions are not included in either agency's
current data collection efforts. For more information, please see section
6.
This report includes data from 212 school districts during the 2018-19 school year
and part of the 2019-20 school year
JLARC staff requested data from 295 public school districts and the Washington School
Information Processing Cooperative (WSIPC). WSIPC is a public nonprofit that performs
personnel-related administrative services for many school districts and maintains
employee and student data for its members.
Overall, 95% of the districts responded to our request: 279 of 295 school districts
and three charter schools submitted data directly to JLARC. WSIPC provided data for
the 276 school districts and two charter schools that use its business services. Due
to the challenges of retroactively pulling data from prior school years and aligning
data from multiple data sources, JLARC staff were able to assemble data from 212
districts.
The 212 districts included in this study reflect the variation in district size and
geographic distribution across all 295 school districts (see Appendix
B). When compared to OSPI personnel data, the number of employees included in
this study represents 65% of total school district employees.
Preliminary Report: School Employees Benefits Board (SEBB) Coverage
October 2021
Report Details
2. One percent reduction in employees
Based on data from 212 districts, the number of full-time
employees increased and the number of part-time employees decreased between the 2018-19
and 2019-20 school years, for a 1% net reduction
JLARC staff collected information from school districts about employees, eligibility
for benefits, and costs. This report presents the data by position type and hours
worked.
JLARC staff collected data on 13 position types based on the Office of the
Superintendent of Public Instruction's (OSPI) personnel reporting database (Exhibit
2.1). Five of the position types are for certificated employees and eight are for
classified employees.
Certificated employees are defined in statute as individuals with a
professional certificate authorized by the Washington Professional Educator
Standards Board.
Classified employees do not hold a professional education certificate.
Exhibit 2.1: JLARC data includes five certificated and eight classified types of
school employee positions
Technical: computer operator or programmer, technician
Transportation: bus driver
Source: JLARC staff analysis.
JLARC staff split the employee data into three categories based on the number of
hours worked: part-time working fewer than 630 hours, part-time working 630 hours or
more, and full-time.
Districts reported a total of 125,135 employees during the 2019-20 school year. Over
half (55%) worked full-time.
The 212 districts reported that 125,135 employees worked during the 2019-20 school
year, a 1% reduction from the 125,990 employees that districts reported for the
2018-19 school year. The percentages of full- and part-time employees were similar for
both school years. During the 2019-20 school year, 55% of employees worked full-time.
Of the part-time employees, 54% worked fewer than 630 hours and 46% worked 630 hours
or more.
Complete district data is available in Appendix
A.
Exhibit 2.2: The number of full- and part-time employees was similar for both school
years
Source: JLARC staff analysis of school district and WSIPC data.
Instructional, paraprofessional, and substitute positions accounted for 64% of all
employees
JLARC staff asked districts to report numbers of employees in 13 major position
types. During the 2019-20 school year, the position types with the most employees were
instructional staff (34% of all employees), paraprofessionals (17%) and substitutes
(13%). Exhibit 2.3 displays the number of employees by position type and hours worked
for the 2019-20 school year.
Exhibit 2.3: During the 2019-20 school year, 70,503 certificated and 54,632
classified employees worked in 212 districts
Certificated/Classified
Position Type
Part-Time Fewer Than 630 Hours
Part-Time 630 Hours or More
Full-Time
Total (% of Total)
Certificated
Administrative
80
601
2,694
3,375 (3%)
Coach
268
44
83
395 (0.3%)
ESA/librarian
644
1,131
5,204
6,979 (6%)
Instructional
936
3,217
38,538
42,691 (34%)
Substitute
14,880
1,057
101
16,038 (13%)
Other positions (certificated)
993
16
16
1,025 (1%)
Total certificated employees
17,801
6,066
46,636
70,503 (56%)
Classified
Custodian/food service/safety
861
3,494
3,898
8,253 (7%)
Director/supervisor
61
184
1,097
1,342 (1%)
Maintenance and grounds
108
88
1,128
1,324 (1%)
Office/clerical
409
1,162
5,097
6,668 (5%)
Paraprofessional
2,507
11,319
7,673
21,499 (17%)
Professional
4,300
968
1,012
6,280 (5%)
Technical
51
252
910
1,213 (1%)
Transportation
306
2,055
1,794
4,155 (3%)
Other positions (classified)
3,583
270
45
3,898 (3%)
Total classified employees
12,186
19,792
22,654
54,632 (44%)
Total employees
29,987
25,858
69,290
125,135 (100%)
Source: JLARC staff analysis of school district and WSIPC data.
Note: For this report, the substitute position type includes both certificated and
classified employees. Exhibit 2.3 also includes "other" categories. Eighteen districts
reported employees in other categories, such as certificated or classified hourly and
on leave. Percentages may not add due to rounding.
The number of substitute employees decreased by 12% between the school years, likely
due to COVID-19-related school closures
Between the 2018-19 to 2019-20 school years, the number of employees in most position
types did not change substantially. The position type with the largest change was
substitute employees. Stakeholders expressed particular interest in this position type
during preliminary research for this study. There were 18,204 substitutes reported in
2018-19 and 16,038 in 2019-20, a 12% decrease. The change varied by hour categories,
as seen in Exhibit 2.4.
Exhibit 2.4: The total number of substitute employees decreased by 12% from the
2018-19 to the 2019-20 school year
Source: JLARC staff analysis of school district data.
In March 2020, all school buildings in Washington closed due to the COVID-19
pandemic. During the summer of 2020, OSPI surveyed districts to learn about staffing
changes resulting from COVID-19. Survey results indicated that most employees under
contract maintained their employment for the duration of the 2019-20 school year.
However, the majority of districts reported that many substitute employees became
eligible for unemployment due to school closures. In addition, many districts
commented to JLARC staff that COVID-19 changed their normal hiring patterns for
substitute employees. Together, these indicate that COVID-19 may have contributed to
the decrease in substitute employees.
Preliminary Report: School Employees Benefits Board (SEBB) Coverage
October 2021
Report Details
3. More employees eligible for benefits under SEBB
Based on data from 212 school districts, 77% of employees were
eligible for health benefits under SEBB, compared to 68% during the 2018-19 school
year
Under the School Employees Benefits Board (SEBB), school employees are eligible for
benefits if they work, or are anticipated to work, 630 hours or more per school year
(September 1 to August 31). Work hours are based on all compensated hours, including
sick leave, personal leave, and paid holidays. Prior to SEBB, eligibility criteria
were locally negotiated between each school district and bargaining unit.
Employees working fewer than 630 hours generally are not eligible for SEBB benefits.
However, employees may be eligible if they start a benefits-eligible position midyear,
if they were anticipated to work 630 hours but didn't, or if the district extends
eligibility to employees working fewer than 630 hours through a collective bargaining
agreement.
Once employees become eligible, they receive benefits for the entire school year
unless employment terminates before the school year ends.
96,346 employees (77%) were eligible for health benefits between January and August
2020 under SEBB
SEBB went into effect during the 2019-20 school year. For the remainder of this
report, data reported under SEBB is for January-August 2020 of the 2019-20 school
year.
Under SEBB, 96,346 (77%) of all district employees were eligible for health benefits.
For comparison, 86,194 (68%) were eligible in the 2018-19 school year.
For both school years, the majority of employees eligible for benefits worked
full-time. Under SEBB, a larger percentage of part-time employees working 630 hours or
more became eligible for benefits (97% compared to 70% in the 2018-19 school year).
However, fewer part-time employees working less than 630 hours were eligible for
benefits under SEBB than in the prior school year (7% under SEBB compared to 8% in
2018-19).
Exhibit 3.1: Under SEBB, the number of employees eligible for health benefits
increased for full-time and part-time employees working 630 hours or more
Source: JLARC staff analysis of school district and WSIPC data.
Note: Data reported under SEBB refers to January-August 2020 of the 2019-20 school
year.
The percentage of eligible employees did not change for most position types
For most position types, the percentage of employees eligible for benefits did not
change substantially after the implementation of SEBB. However, paraprofessionals and
transportation employees had a larger change compared to other position types. During
the 2018-19 school year, 77% of transportation and 75% of paraprofessionals were
eligible for health benefits. This increased to 95% and 91% respectively under SEBB.
Exhibit 3.2: Aside from transportation and paraprofessionals, most position types
saw a small change in percentage of eligible employees between 2018-19 and SEBB
Source: JLARC staff analysis of school district and WSIPC data.
Note: This graphic highlights all position types with fewer than 40% of employees
eligible for benefits and the two positions types with the greatest change in employee
eligibility.
More detail about changes within position types, including by hours worked, is
available in Appendix
A.
Fewer employees (12%) waived medical coverage under SEBB than in 2018-19 (18%)
The number of employees waiving medical coverage under SEBB was 12,030 (12%) in
comparison to 15,245 (18%) in the 2018-19 school year. Exhibit 3.3 illustrates the
number of employees waiving coverage, broken down by hours worked and certificated or
classified position types. Classified part-time employees had the largest change in
number waiving coverage: 7,081 waived in the 2018-19 school year and 4,854 waived
under SEBB.
Exhibit 3.3: Fewer employees waived medical coverage under SEBB than in the 2018-19
school year
Source: JLARC staff analysis of school district data.
By position type, the largest changes in waived coverage were for transportation,
paraprofessionals, and other (certificated and classified) employees.
Exhibit 3.4: The largest changes in percentage of employees waiving coverage were
for transportation, paraprofessionals, and other position types
Source: JLARC staff analysis of school district data.
Note: This graphic highlights all position types with greater than 30% of employees
waiving benefits and the position types with the greatest change in percentage of
employees waiving coverage.
Preliminary Report: School Employees Benefits Board (SEBB) Coverage
October 2021
Report Details
4. Districts paid more under SEBB
On average, the 212 school districts paid an estimated 31-44% more
per month for employee health benefits under SEBB than during the 2018-19 school
year
Prior to SEBB, each district selected and negotiated insurance plans independently.
Benefit packages were developed through collective bargaining and varied within and
among districts. For example, a district may have offered different plans for
certificated, classified, part-time, and full-time employees. This resulted in highly
variable monthly rates across the state.
Under SEBB, all districts pay the same monthly employer rate for each employee. From
January through August 2020, the average monthly rate was $1,010The SEBB rate was $994 for January–June 2020, and
$1,056 for July and August 2020..
The SEBB employer rate for January-August 2020 included:
Medical, dental, and vision premiums.
Basic life, accidental death and dismemberment, and long-term disability
premiums.
K-12 remittance (subsidy payment to the Health Care Authority (HCA) to reflect
costs of allowing retired school district employees to enroll in self-paid Public
Employee Benefits Board (PEBB) coverage).
Administrative costs.
One-time start-up costs.
Employees pay an additional medical premium that varies depending on the benefit plan
they select and whether they cover dependents.
Districts' average cost increase of 31-44% accounts for potential
underreporting
JLARC staff asked districts to report their costs for employee health benefits for
the 2018-19 and 2019-20 school years. Under SEBB (January-August of the 2019-20 school
year), all school districts paid the same monthly rate per employee for health
benefits. However, costs for health benefits during the 2018-19 school year varied.
Differences in district accounting and payroll systems further hindered cost
comparisons between districts and years. For the 2018-19 school year, some districts
reported all costs associated with providing health benefits, and some excluded
administrative costs (e.g., brokerage fees, network access fees, taxes), non-medical
benefits, and/or the K-12 remittance. This exclusion may have resulted in
underreporting of up to 10% of the total reported benefit costs in 2018-19.
Given this potential underreporting, JLARC staff estimate that school districts paid
an average of 31% to 44% more for employee health benefits under SEBB. The low end of
the range assumes that the districts underreported their costs by 10% in 2018-19. The
high end of the range is based on the actual district reported costs.
Three factors contributed to the increase in district costs under SEBB
Three main factors contribute to the cost increase under SEBB. JLARC staff estimated
the proportion of the increase that can be attributed to each of these factors. The
ranges below account for district-reported costs in 2018-19 and the potential for 10%
underreporting of costs.
Exhibit 4.1: Higher monthly employer rate, expanded eligibility, and change in
employer contribution for part-time employees affected district costs under SEBB
Factors Affecting Costs
Estimated Portion of Cost Increase Using District Reported Costs
for 2018-19
Estimated Portion of Cost Increase Assuming a 10% Underreporting
of District Costs for 2018-19
1. Higher monthly employer rate (amount districts pay per
employee)
Prior to SEBB, each school district negotiated health benefits separately.
Rates varied depending on the district and/or bargaining unit. Under SEBB,
the monthly employer rate is the same for all school district employees
statewide.
The SEBB rate is comprehensive. It includes all benefits, administrative
costs, and the K-12 remittance. Prior to SEBB, these costs may have been
accounted for separately.
53%
36%
2. More employees are eligible and covered
More employees became eligible for benefits under SEBB.
Fewer employees waived coverage. Prior to SEBB, districts may not have
been responsible for the employer portion of locally or federally funded
employees waiving medical coverage. Districts were responsible for the
employer portion of state-funded employees.
30%
39%
3. School districts pay the full employer contribution for part-time
employees
Under SEBB, districts pay the full employer contribution for part-time
employees. Prior to SEBB, districts may have paid a prorated amount based on
employee full-time equivalency (FTE).
17%
25%
Total
100%
100%
Source: JLARC staff analysis of school district and WSIPC data.
Going forward, all districts will pay the full employer contribution for part-time
employees rather than a prorated amount. As a result, changes to the monthly employer
rate and expanded eligibility will drive any future cost increases.
Average monthly costs at 212 reporting districts increased from $40.7 million to
$54.6 million for certificated employees and $27.1 million to $42.9 million for
classified employees
The average monthly cost for school districts increased for all employee groups
(certificated and classified, part-time and full-time). Overall, costs increased from
$40.7 million to $54.6 million for certificated employees and from $27.1 million to
$42.9 million for classified employees. While the majority of districts' costs are for
full-time certificated employees, the largest cost increases by percentage are for
part-time employees (Exhibit 4.2).
Exhibit 4.2: Most districts' monthly costs are for full-time employees. The largest
monthly cost increases are for part-time employees.
Source: JLARC staff analysis of school district and WSIPC data.
Preliminary Report: School Employees Benefits Board (SEBB) Coverage
October 2021
Report Details
5. State funding increased under SEBB
For 212 reporting districts, the state funded 2% more
certificated benefit units and 25% more classified benefit units under SEBB
The Legislature provides funding in the biennial operating budget for school employee
salaries and benefits, supplies, equipment, and other school operating costs. The
majority of funding is determined by a prototypical school model that estimates school
expenses, including the total number of certificated and classified full-time
equivalent (FTE) employees for a hypothetical number of enrolled students. "Benefit
unit" refers to the number of FTEs funded in the operating budget multiplied by an
additional rate (called the benefit allocation factor) to recognize that more than one
individual may fill a position and each may be eligible for benefits. The funding
process did not change under SEBB.
The Legislature provides OSPI with funds for school employee health benefits
Each biennium, the Legislature appropriates funds for basic education to the Office
of Superintendent of Public Instruction (OSPI). Part of this appropriation is intended
for employee health benefits. Basic education is comprised of nine programs (see
Exhibit 5.3 for list of programs included in this study). For most basic education
programs, health benefits funding is based on three components (Exhibit 5.1):
The total number of certificated and classified FTEs funded in the operating
budget. These are calculated through formulas based on projected student enrollment
and other statewide characteristics. The formulas did not change under SEBB.
The benefit allocation factor (BAF) applied to the number of FTEs funded in the
budget. The BAF provides additional funding per FTE to recognize that more than one
individual may fill a position and each may qualify for benefits. For example, if a
full-time paraprofessional position is filled by two part-time employees, the BAF
increases funding in the budget to address the fact that both employees may qualify
for benefits. Beginning in January 2020, the BAF amounts were 1.02 for certificated
employees and 1.43 for classified employees. The BAF for certificated employees
began under SEBB and the BAF for classified employees increased under SEBB from
1.152 during the 2018-19 school year.
The monthly health benefit rate per benefit unit. HCA recommends a monthly rate
through the Governor's budget proposal. The Legislature sets the actual rate in the
biennial operating budget. In 2018-19, the funding rate was $844 per month. Under
SEBB, the funding rate increased to an average of $1,010The SEBB rate was $994 for
January–June 2020, and $1,056 for July and August 2020.
per month.
Exhibit 5.1: Health benefits funding is determined by three main components: FTEs,
BAF, and the health benefit rate
Source: JLARC staff analysis of the K-12 funding process.
OSPI distributes funding to school districts using a series of funding formulas that
adjust for specific district circumstances, including actual student enrollment and
regional and demographic differences.
School districts have discretion in the number and type of employees they hire. At a
minimum, all school districts must offer health benefits to employees who meet the
state's eligibility criteria. Since January 1, 2020, all school employees who work, or
are anticipated to work, 630 hours or more per year are eligible for health benefits.
School districts send monthly payments to the Health Care Authority (HCA)to
cover the costs of employee benefits provided by SEBB. Districts pay the same per
person rate whether an employee chooses to receive or waive benefits.
For 212 districts, the state funded 2% more certificated benefit units and 25% more
classified benefit units under SEBB than in the 2018-19 school year
Under SEBB, the state increased the number of benefit units funded in the operating
budget from 57,680 to 61,923, a 7% increase. The number of certificated benefit units
increased by 2% and the number of classified benefit units increased by 25%.
Exhibit 5.2: Total funded benefit units increased by 7% under SEBB
2018-19
SEBB
% Change
Certificated benefit units
44,153
45,056
2%
Classified benefit units
13,527
16,866
25%
Total benefit units
57,680
61,923
7%
Source: JLARC staff analysis of OSPI data. Totals may not add due to rounding.
For 212 districts, the average monthly allocation for school employee health benefits
increased under SEBB
Under SEBB, average monthly funding increased to $74.1 million from $57.5 million in
the 2018-19 school year, a 29% increase. JLARC staff compared average monthly funding
amounts rather than yearly totals because SEBB was only in effect for part of the
2019-20 school year.
General Apportionment is the largest source of funding for employee health
benefits
The state funds nine major programs as part of the basic education provided to all
students. JLARC staff worked with OSPI to estimate the amount of health benefits funding
from eight of the major programs. The Institutional Educational program, which provides
K-12 education services to current and previously incarcerated youth, is not included in
the funding estimates. This is because not every district has this program and the
employees may be part of the Educational Service District rather than the school
district.
The funding formulas for the Special Education and Pupil Transportation programs are
not based on staffing units, so estimates for these programs reflect the proportion of
the funding that is assumed to cover employee benefits.
Exhibit 5.3: Under SEBB, the General Apportionment program accounted for 73% of
employee health benefits funding at the 212 districts in this study
Funding Program
Certificated Benefit Units
Classified Benefit Units
Average Monthly Funding (January - August 2020)
Proportion of Health Benefits Funding
General Apportionment: Foundational school funding based on a
prototypical school model.
38,005
15,819
$54.3 million/month
73%
Special Education: Funding for the additional costs of providing a basic
education to children who qualify for individualized education programs.
N/A
N/A
$8.8 million/month
12%
Career and Technical Education: Career focused courses for middle and
high school students.
2,413
972
$3.4 million/month
5%
Learning Assistance Program: Additional assistance to students below
grade level in reading, math, and language arts.
2,868
N/A
$2.9 million/month
4%
Pupil Transportation: Transportation of students to and from school.
N/A
N/A
$2.8 million/month
4%
Transitional Bilingual: Additional assistance to students learning
English as a non-primary language.
1,352
N/A
$1.4 million/month
2%
Skill Centers: Regional centers that provide career focused and technical
courses to high school students from multiple districts.
213
75
$0.29 million/month
<1%
Highly Capable Program: Additional assistance for students that qualify
as gifted.
206
N/A
$0.21 million/month
<1%
Total
45,056
16,866
$74.1 million/month
100%
Source: JLARC staff analysis of OSPI funding data between January and August
2020.
Note: The Pupil Transportation monthly health benefits funding estimate does not
include the two districts (Shaw Island and Stehekin) that do not provide pupil
transportation and 14 districts that contract out transportation services to a private
entity.
The state's funding allocation is not intended to match districts' costs
State funding is not intended to match districts' costs because each district has
discretion in how many staff they hire, how many hours those staff work, and other
factors that affect health benefit costs. Districts may hire more or fewer employees
than are accounted for in the funding models. They may also employ locally or federally
funded staff who are eligible for SEBB but not reflected in state funding.
Under SEBB, state funding for health benefits represented 76% of school districts'
collective reported costs at the 212 reporting districts. The ratio of funding to costs
varied across the districts, ranging from a low of 28% to a high of 240%.
Exhibit 5.4: The state funding allocation for benefits represented between 75-99% of
costs for the majority of the 212 reporting districts
Source: JLARC staff analysis of school district and OSPI data.
Note: The 2018-19 district cost data used for this exhibit is based on actual district
reported costs. The costs were not adjusted for potential underreporting.
Preliminary Report: School Employees Benefits Board (SEBB) Coverage
October 2021
Report Details
6. Options for future data collection
Ongoing collection of similar eligibility and cost data would
require changes to OSPI and HCA reporting requirements
Retroactive data collection was challenging and time consuming for school districts
and WSIPC
JLARC staff received data from two main sources: school districts and the Washington
School Information Processing Cooperative (WSIPC). School districts store data in
separate accounting and payroll systems. Many reported that it was not easy to link
the data to answer questions about eligibility and costs by position type and hours
worked. Many districts indicated that they spent a substantial amount of time
obtaining the requested data.
Data collection was also difficult for WSIPC. Districts use different accounting and
payroll systems, and report data to WSIPC consistent with those systems. WSIPC's data
queries for this project were compatible with the formats some districts use, but not
others.
Some school districts indicated that providing this information in the future would
be easier if the data elements were identified beforehand and applied prospectively
rather than retrospectively. This would allow them to align their data systems with
future reporting and eliminate the need to reconstruct data from previous years.
Existing OSPI and HCA data is not detailed enough to answer the study questions on
an ongoing basis
The Office of the Superintendent of Public Instruction (OSPI) and the Health Care
Authority (HCA) collect data relevant to this study, but the data is not detailed
enough to answer the Legislature's questions.
OSPI collects personnel data from school districts.
Districts report a snapshot of detailed employee information each October. This
includes whether an employee is certificated or classified, position type, and
full-time equivalent (FTE). It does not include the number of hours worked per year
or whether the employee is eligible for or receiving SEBB benefits. Collecting
information about hours worked would allow for accurate counts of employees by hour
range.
OSPI does not currently collect data about all position types. For example,
short-term substitutes are not part of the required reporting. Including all
positions would allow for more accurate employee counts.
HCA collects health benefit eligibility data from school districts.
Information about the number of health care subscribers and the number of
employees waiving benefits does not include whether the employee is certificated or
classified, their position type, or number of hours worked. Including the position
type and whether the employee is certificated or classified would allow for
comparison with OSPI personnel data.
HCA does not currently collect information about the number and type of employees
who are not eligible for health benefits.
The information requested for this study is not readily available from existing data
sources without changes to OSPI's and HCA's reporting requirements for school
districts.
Additional information addressing the questions in this study could be collected in
the future by OSPI and HCA, but this would require more work by these agencies and
school districts. Before any new reporting is undertaken, the Legislature should
consider whether this JLARC staff report provides sufficient information or whether
ongoing monitoring is desired.
School districts now report health benefit expenditures to OSPI
Beginning in the 2019-20 school year, school districts are required to report health
benefit expenditures for certificated and classified staff in annual financial reports
to OSPI. The data does not include position types or hours worked. While this new
reporting requirement increases the level of detail available, the data is not enough
to answer all of the Legislature's questions addressed in this report.
Legislative Auditor Recommendation
OSPI and HCA should work with House and Senate fiscal staff to determine what
additional data elements might be needed for ongoing data collection. If new elements
are suggested, OSPI and HCA should each develop a data collection plan and identify
resource requirements as applicable.
Preliminary Report: School Employees Benefits Board Coverage
October 2021
Report Details
Appendix A: Additional statewide and district-level data
This section links to external dashboards
The dashboards are hosted on Tableau Public. You do not need a Tableau account to
access them. Click on the images in the tables below to open interactive dashboards in a
new window.
Statewide summary data on number of employees, eligibility, waived coverage, and
amounts paid
JLARC staff developed summary dashboards that provide additional information about
number of employees, eligibility, waived coverage, and amounts paid by position types
and hours worked. The data is for the 212 districts included in this study.
Data
Data Source
Link
Number of employees
School districts and/or Washington School Information Processing Cooperative
(WSIPC)
Number eligible for health benefits
School districts and/or WSIPC
Number waiving coverage
School districts
Amount paid by districts for employee health benefits
School districts and/or WSIPC
District-level raw data
212 school districts reported data to JLARC staff for the 2018-19 and 2019-20 school
years. The data includes number and type of employees, eligibility for health benefits,
waived coverage, and amount the districts paid for employee health benefits.
Data notes:
Amount paid: The amount paid under SEBB reflects an eight-month period. SEBB
went into effect on January 1, 2020, partway through the 2019-20 school year. The
amount paid for 2018-19 reflects the full benefit year (12 months).
Full-time definitions: School districts use different definitions for
full-time. For example, some districts consider an administrator full-time if they
work 1,720 hours per year. Others consider an administrator full-time if they work
2,080 hours per year. The data in the district dashboard appears exactly as reported
by each school district or WSIPC. For the statewide results presented in this report
and the summary dashboards, JLARC staff used the median definition of full-time
reported for each position.
Data
Data Source
Link
District-level data
School districts and/or WSIPC
State funding data for employee health benefits
The funding dashboard shows estimated certificated and classified benefit units and
average monthly funding by district for 2018-19 and SEBB. A "benefit unit" refers to the
number of FTEs funded in the operating budget multiplied by an additional rate (called
the benefit allocation factor) to recognize that more than one individual may fill a
position and each may be eligible for benefits. Funding is shown for eight basic
education programs.
Data
Data Source
Link
State funding for employee health benefits
Office of Superintendent of Public Instruction (OSPI)
Preliminary Report: School Employees Benefits Board (SEBB) Coverage
October 2021
Report Details
Appendix B: Districts included in this study
212 school districts included in study
School districts included in the study are distributed across the state.
Exhibit B1: Map of the 212 districts included in this study
JLARC staff compared the proportion of districts included in this study to the
proportion of all 295 districts that are:
Located within each Educational Service District as a measure of geographic
representation.
Categorized within different district size classesVery small = under 500 students, small = 500-999 students,
medium = 1,000-4,999 students, large = 5,000-9,999 students, very large = 10,000
students or more. based on student enrollment.
Exhibit B2: The 212 districts are located in all nine Educational Service Districts
and are distributed in a similar manner to all districts statewide
Educational Service District (ESD)
All Districts
Percent of All Districts
Districts Included in This Study
Percent of Districts Included in This Study
ESD 101 (Northeast Washington)
59
20%
42
20%
ESD 105
25
8%
19
9%
ESD 112
30
10%
17
8%
ESD 113 (Capital Region)
44
15%
36
17%
ESD 114 (Olympic)
15
5%
13
6%
ESD 121 (Puget Sound)
35
12%
26
12%
ESD 123
23
8%
16
8%
ESD 171 (North Central)
29
10%
23
11%
ESD 189 (Northwest)
35
12%
20
9%
Total
295
100%
212
100%
Exhibit B3: The 212 districts are representative of the size distribution of all
districts statewide
District Size
All Districts
Percent of All Districts
Districts Included in This Study
Percent of Districts Included in This Study
Very small (less than 500 students)
101
34%
71
33%
Small (500-999 students)
46
16%
34
16%
Medium (1,000-4,999 students)
87
29%
68
32%
Large (5,000-9,999 students)
27
9%
18
8%
Very large (10,000+ students)
34
12%
21
10%
Total
295
100%
212
100%
Preliminary Report: School Employees Benefits Board (SEBB) Coverage
(1) The school employees' benefits board is created within the authority. The
function of the school employees' benefits board is to design and approve insurance
benefit plans for school employees and to establish eligibility criteria for
participation in insurance benefit plans.
(2) By September 30, 2017, the governor shall appoint the following voting members to
the school employees' benefits board as follows: (a) Two members from associations
representing certificated employees; (b) Two members from associations representing
classified employees; (c) Four members with expertise in employee health benefits
policy and administration, one of which is nominated by an association representing
school business officials; and (d) The director of the authority or his or her
designee.
(3) Initial members of the school employees' benefits board shall serve staggered
terms not to exceed four years. Members appointed thereafter shall serve two-year
terms.
(4) Compensation and reimbursement related to school employees' benefits board member
service are as follows: (a) Members of the school employees' benefits board must be
compensated in accordance with RCW 43.03.250 and must be reimbursed for their travel
expenses while on official business in accordance with RCW 43.03.050 and 43.03.060.
(b) While school employees' benefits board members are carrying out their powers and
duties under chapter 41.05 RCW, if the service of any certificated or classified
employee results in a need for a school employees' benefits board organization to
employ a substitute for such certificated or classified employee during such service,
payment for such a substitute may be made by the authority from funds appropriated by
the legislature for the school employees' benefits board program. If such substitute
is paid by the authority, no deduction shall be made from the salary of the
certificated or classified employee. In no event shall a school employees' benefits
board organization deduct from the salary of a certificated or classified employee
serving on the school employees' benefits board more than the amount paid the
substitute employed by the school employees' benefits board organization.
(5) The director of the authority or his or her designee shall be the chair and
another member shall be selected by the school employees' benefits board as vice
chair. The chair shall conduct meetings of the school employees' benefits board. The
vice chair shall preside over meetings in the absence of the chair. The school
employees' benefits board shall develop bylaws for the conduct of its business.
(6) The school employees' benefits board shall: (a) Study all matters connected with
the provision of health care coverage, life insurance, liability insurance, accidental
death and dismemberment, and disability insurance, or any of, or combination of, the
enumerated types of insurance for eligible school employees and their dependents on
the best basis possible with relation both to the welfare of the school employees and
the state. However, liability insurance should not be made available to dependents;
(b) Develop school employee benefit plans that include comprehensive, evidence-based
health care benefits for school employees. In developing these plans, the school
employees' benefits board shall consider the following elements: (i) Methods of
maximizing cost containment while ensuring access to quality health care; (ii)
Development of provider arrangements that encourage cost containment and ensure access
to quality care including, but not limited to, prepaid delivery systems and
prospective payment methods; (iii) Wellness, preventive care, chronic disease
management, and other incentives that focus on proven strategies; (iv) Utilization
review procedures to support cost-effective benefits delivery; (v) Ways to leverage
efficient purchasing by coordinating with the public employees' benefits board; (vi)
Effective coordination of benefits; and (vii) Minimum standards for insuring entities;
(c) Authorize premium contributions for a school employee and the employee's
dependents in a manner that encourages the use of cost-efficient health care systems.
For participating school employees, the required school employee share of the cost for
family coverage premiums may not exceed three times the premiums for a school employee
purchasing single coverage for the same coverage plan;
(d)
Determine the terms and conditions of school employee and dependent eligibility
criteria, enrollment policies, and scope of coverage. At a minimum, the eligibility
criteria established by the school employees' benefits board shall address the
following: (i) The effective date of coverage following hire; (ii) The benefits
eligibility criteria, but the school employees' benefits board's criteria shall be no
more restrictive than requiring that a school employee be anticipated to work at least
six hundred thirty hours per school year to be benefits eligible; and (iii) Coverage
for dependents, including criteria for legal spouses; children up to age twenty-six;
children of any age with disabilities, mental illness, or intellectual or other
developmental disabilities; and state registered domestic partners, as defined in RCW
26.60.020, and others authorized by the legislature; (e) Establish terms and
conditions for a school employees' benefits board organization to have the ability to
locally negotiate eligibility criteria for a school employee who is anticipated to
work less than six hundred thirty hours in a school year. A school employees' benefits
board organization that elects to use a lower threshold of hours for benefits
eligibility must use benefits authorized by the school employees' benefits board and
shall do so as an enrichment to the state's definition of basic
education; (f) Establish penalties to be
imposed when a school employees' benefits board organization fails to comply with
established participation criteria; and (g) Participate with the authority in the
preparation of specifications and selection of carriers contracted for school employee
benefit plan coverage of eligible school employees in accordance with the criteria set
forth in rules. To the extent possible, the school employees' benefits board shall
leverage efficient purchasing by coordinating with the public employees' benefits
board.
(7) School
employees shall choose participation in one of the health care benefit plans developed
by the school employees' benefits board. Individual school employees eligible for
benefits under subsection (6)(d) of this section may be permitted to waive coverage
under terms and conditions established by the school employees' benefits
board.
(8) By November 30, 2021, the authority shall review the benefit plans provided
through the school employees' benefits board, complete an analysis of the benefits
provided and the administration of the benefits plans, and determine whether
provisions in chapter 13, Laws of 2017 3rd sp. sess. have resulted in cost savings to
the state. The authority shall submit a report to the relevant legislative policy and
fiscal committees summarizing the results of the review and analysis.
[ 2018 c 260 § 1; 2017 3rd sp.s. c 13 § 801.]
Employer contribution for school employees benefits board (SEBB) benefits.
WAC 182-30-030
The employer contribution must be used to provide school employees benefits board
(SEBB) insurance coverage for the basic life insurance benefit, basic accidental death
and dismemberment (AD&D) insurance benefit, basic long-term disability (LTD)
insurance benefit, medical insurance, vision insurance, dental insurance, SEBB program
administrative costs, the school employee remittance required in RCW 28A.400.410 and
to establish a reserve for any remaining balance. There is no employer contribution
available for any other insurance coverage for school employees employed by SEBB
organizations.
[Statutory Authority: RCW 41.05.021, 41.05.160, 2017 3rd sp.s. c 13, 2018 c 260, and
SEBB policy resolutions. WSR 19-14-093 (Admin #2019-01), § 182-30-030, filed 7/1/19,
effective 8/1/19.]
The employer contribution is set by the health care authority (HCA) and paid to the
HCA for all eligible school employees.
WAC 182-30-070
School employees benefits board (SEBB) organizations must pay the employer
contributions to the health care authority (HCA) for SEBB insurance coverage for all
eligible school employees and their enrolled dependents.
(1) Employer contributions are set by the HCA, and are subject to the approval of the
governor for availability of funds as specifically appropriated by the legislature for
that purpose. The employer contribution for school employees eligible under RCW
41.05.740 (6)(e) are set by the HCA.
(2) Employer contributions must include an amount determined by the HCA to pay
administrative costs to administer SEBB benefits for school employees.
(3) Each school employee of a SEBB organization on leave under the federal Family and
Medical Leave Act (FMLA) or the paid family medical leave program is eligible for the
employer contribution as described in WAC 182-31-110.
(4) The entire employer contribution is due and payable to HCA even if SEBB medical
is waived as described in WAC 182-31-080, except for school employees eligible under
WAC 182-30-130.
What are the requirements for a school employees benefits board (SEBB) organization
engaging in local negotiations regarding SEBB benefits eligibility criteria?
WAC 182-30-130
This section describes the terms and conditions for a school employees benefits board
(SEBB) organization that is engaging in local negotiations regarding eligibility for
school employees as described in RCW 41.05.740 (6)(e).
(1) A SEBB organization must provide a current ratified collective bargaining
agreement (CBA) and information on all eligible school employees under the CBA to the
health care authority (HCA) by the start of the school year.
(2) A SEBB organization must offer all of, and only, the following SEBB benefits to
employees and their dependents: (a) Medical (includes the wellness incentive); (b)
Dental; (c) Vision; (d) Basic life; (e) Basic accidental death and dismemberment
(AD&D) insurance.
(3) A SEBB organization must provide an employer contribution as described below: (a)
The subscriber-only employer medical contribution (EMC) amount for school employees
eligible under RCW 41.05.740 (6)(d) multiplied by the premium tier ratio associated
with the enrollment tier selected by the school employee; (b) One hundred percent of
the cost for the school employee dental plan multiplied by the enrollment tier
selected by the school employee; (c) One hundred percent of the cost for the school
employee vision plan multiplied by the enrollment tier selected by the school
employee; (d) One hundred percent of the cost for basic life and accidental death and
dismemberment (AD&D) insurance; (e) One hundred percent of the cost of the
administrative fee charged by the HCA; and (f) One hundred percent of the monthly K-12
remittance for deposit in the retired school employees' subsidy account.
(4) A SEBB organization providing SEBB benefits as described in this section may do
so by group as described in (a) through (d) of this subsection: (a) The entire SEBB
organization; (b) A entire collective bargaining unit; (c) A group containing all
nonrepresented school employees; or (d) A combination of (b) and (c) of this
subsection.
(5) A SEBB organization must establish a threshold of anticipated work hours no less
than one hundred eighty hours but less than the minimum hours to meet SEBB eligibility
under WAC 182-31-040 within a school year.
(6) All of the rules in chapters 182-30, 182-31, and 182-32 WAC apply, except for all
rules governing SEBB benefits that are not available to school employees whose
eligibility is established under this section. The following benefits are not
available to school employees whose eligibility is established under this section: (a)
Long-term disability (LTD); (b) Medical flexible spending arrangement (FSA); (c)
Dependent care assistance program (DCAP); and (d) Supplemental life insurance.
(7) If a school employee waives medical under this section, there is no requirement
to send the employer contribution to the HCA as required in WAC 182-30-070(4).
(8) Eligibility determinations must align with the SEBB program's status as a
governmental plan under Section 3(32) of the Employee Retirement Income Security Act
of 1974 (ERISA) as amended. This means the SEBB organization may only consider school
employees whose services are substantially all in the performance of essential
governmental functions, but not in the performance of commercial activities, whether
or not those activities qualify as essential governmental functions to be eligible.
(9) A SEBB organization providing SEBB benefits to a group of school employees under
this section must notify the SEBB program each time the CBA is renegotiated.
How do school employees establish eligibility for the employer contribution toward
school employees benefits board (SEBB) benefits and when do SEBB benefits begin?
WAC 182-31-040
(1) Eligibility shall be determined solely by the criteria that most closely
describes the school employee's work circumstance.
(2) School employee eligibility criteria: (a) A school employee is eligible for the
employer contribution toward school employees benefits board (SEBB) benefits if they
are anticipated to work at least six hundred thirty hours per school year. The
eligibility effective date for a school employee eligible under this subsection shall
be determined as follows: (i) If the school employee's first day of work is on or
after September 1st but not later than the first day of school for the current school
year as established by the SEBB organization, they are eligible for the employer
contribution on the first day of work; or (ii) If the school employee's first day of
work is at any other time during the school year, they are eligible for the employer
contribution on that day. (b) A school employee who is not anticipated to work at
least six hundred thirty hours in the school year becomes eligible for the employer
contribution toward SEBB benefits on the date their work pattern is revised in such a
way that they are now anticipated to work six hundred thirty hours in the school year.
(c) A school employee who is not anticipated to work at least six hundred thirty hours
in the school year becomes eligible for the employer contribution toward SEBB benefits
on the date they actually worked six hundred thirty hours in the school year. (d) A
school employee who is not anticipated to work six hundred thirty hours within the
school year because of the time of year they are hired but is anticipated to work at
least six hundred thirty hours the next school year, establishes eligibility for the
employer contribution toward SEBB benefits as of their first working day if they are:
(i) A nine to ten month school employee anticipated to be compensated for at least
seventeen and one-half hours a week in six of the last eight weeks counting backwards
from the week that contains the last day of school; or (ii) A twelve month school
employee anticipated to be compensated for at least seventeen and one-half hours a
week in six of the last eight weeks counting backwards from the week that contains
August 31st, the last day of the school year.
(3) All hours worked by an employee in their capacity as a school employee must be
included in the calculation of hours for determining eligibility. All hours for which
a school employee receives compensation from a SEBB organization during an approved
leave (e.g., sick leave, personal leave, bereavement leave) or a paid holiday must be
included when determining how many hours a school employee is anticipated to work, or
did work, in the school year.
(4) A school employee may establish eligibility for the employer contribution toward
SEBB benefits by stacking of hours from multiple positions within one SEBB
organization. A school employee may not gain eligibility by stacking of hours from
multiple SEBB organizations.
(5) A school employee is presumed eligible for the employer contribution at the start
of the school year, as described in subsection (2)(a) of this section, if they: (a)
Worked at least six hundred thirty hours in each of previous two school years; and (b)
Are returning to the same type of position (teacher, paraeducator, food service
worker, custodian, etc.) or combination of positions with the same SEBB organization.
Note: A SEBB organization rebuts this presumption by notifying the school employee, in
writing, of the specific reasons why the school employee is not anticipated to work at
least six hundred thirty hours in the current school year and how to appeal the
eligibility determination.
(6) A school employee who returns from approved leave without pay will maintain or
establish eligibility for the employer contribution toward SEBB benefits if their work
schedule, had it been in effect at the start of the school year, would have resulted
in the school employee being anticipated to work the minimum hours to meet SEBB
eligibility for the employer contribution in the school year. A school employee who
regains eligibility under this subsection establishes eligibility for the employer
contribution toward SEBB benefits as of the date they returned from approved leave
without pay.
(7) When SEBB benefits begin: (a) For a school employee who establishes eligibility
under subsection (2)(a)(i) of this section, medical, dental, vision, basic life
insurance, basic accidental death and dismemberment (AD&D) insurance, basic
long-term disability (LTD) insurance, and if eligible, benefits under the salary
reduction plan begin on the first day of work for the new school year. Supplemental
life insurance, supplemental AD&D insurance, and supplemental LTD insurance begin
on the first day of the month following the date the contracted vendor receives the
required form or approves the enrollment. (b) For a school employee who establishes
eligibility under subsection (2)(a)(ii), (b), (c), (d), or (6) of this section,
medical, dental, vision, basic life insurance, basic AD&D insurance, basic LTD
insurance, and if eligible, benefits under the salary reduction plan begin on the
first day of the month following the date the school employee becomes eligible for the
employer contribution toward SEBB benefits. Supplemental life insurance, supplemental
AD&D insurance, and supplemental LTD insurance begin on the first day of the month
following the date the contracted vendor receives the required form or approves the
enrollment. Exception: When a school employee establishes eligibility for the employer
contribution toward SEBB benefits as described under subsection (2)(b) or (c), or (6)
of this section, at any time in the month of August, SEBB benefits begin on September
1st only if the school employee is also determined to be eligible for the employer
contribution toward SEBB benefits for the school year that begins on September 1st.
(8) If the school employee is not eligible under subsections (1) through (6) of this
section, they may be eligible for SEBB benefits if their SEBB organization is engaging
in local negotiations regarding eligibility for school employees as described in WAC
182-30-130.
When does eligibility for the employer contribution for school employees
benefits board (SEBB) benefits end?
WAC 182-31-050
(1) The employer contribution toward school employees benefits board (SEBB) benefits
ends the last day of the month in which the school year ends. The employer
contribution toward SEBB benefits will end earlier than the end of the school year if
one of the following occurs: (a) The SEBB organization terminates the employment
relationship. In this case, eligibility for the employer contribution ends the last
day of the month in which the employer-initiated termination notice is effective; (b)
The school employee terminates the employment relationship. In this case, eligibility
for the employer contribution ends the last day of the month in which the school
employee's resignation is effective; or (c) The school employee's work pattern is
revised such that the school employee is no longer anticipated to work six hundred
thirty hours during the school year. In this case, eligibility for the employer
contribution ends as of the last day of the month in which the change is effective.
(2) If the SEBB organization deducted the school employee's portion of the premium
for SEBB benefits from their pay after the school employee was no longer eligible for
the employer contribution, SEBB benefits end the last day of the month for which
school employee premiums were deducted.
When may a school employee waive enrollment in school employees benefits board
(SEBB) medical and when may they enroll in SEBB medical after having waived
enrollment?
WAC 182-31-080
A school employee may waive enrollment in school employees benefits board (SEBB)
medical if they are enrolled in other employer-based group medical, a TRICARE plan, or
medicare as described in subsection (1)(a) through (c) of this section. A special open
enrollment event must be an event other than a school employee gaining initial
eligibility for SEBB benefits. A school employee who waives enrollment in SEBB medical
must enroll in dental, vision, basic life insurance, basic accidental death and
dismemberment (AD&D) insurance, and basic long-term disability insurance.
(1) To waive enrollment in SEBB medical, the school employee must submit the required
form to their SEBB organization at one of the following times: (a) When the school
employee becomes eligible: A school employee may waive SEBB medical when they become
eligible for SEBB benefits. The school employee must indicate their election to waive
enrollment in SEBB medical on the required form and submit the form to their SEBB
organization. The SEBB organization must receive the form no later than thirty-one
days after the date the school employee becomes eligible for benefits (see WAC
182-30-080). SEBB medical will be waived as of the date the school employee becomes
eligible for SEBB benefits. (b) During the annual open enrollment: A school employee
may waive SEBB medical during the annual open enrollment. The required form must be
received by the school employee's SEBB organization before the end of the annual open
enrollment. SEBB medical will be waived beginning January 1st of the following year.
(c) During a special open enrollment: A school employee may waive SEBB medical during
a special open enrollment as described in subsection (4) of this section. The school
employee must submit the required form to their SEBB organization. The SEBB
organization must receive the form no later than sixty days after the event that
creates the special open enrollment. In addition to the required form, the school
employee must provide evidence of the event that creates the special open enrollment
to their SEBB organization. SEBB medical will be waived the last day of the month
following the later of the event date or the date the required form is received. If
that day is the first of the month, SEBB medical will be waived the last day of the
previous month. If the special open enrollment is due to the birth, adoption, or
assumption of legal obligation for total or partial support in anticipation of
adoption of a child, SEBB medical will be waived the last day of the previous month.
(2) If a school employee waives SEBB medical, the school employee may not enroll
dependents in SEBB medical.
(3) Once SEBB medical is waived, the school employee is only allowed to enroll in
SEBB medical at the following times: (a) During the annual open enrollment. The
required form must be received by the school employee's SEBB organization before the
end of the annual open enrollment. SEBB medical will begin January 1st of the
following year. (b) During a special open enrollment. A special open enrollment allows
a school employee to revoke their election and make a new election outside of the
annual open enrollment. A special open enrollment may be created when one of the
events described in subsection (4) of this section occurs. The school employee must
submit the required form to their SEBB organization. The SEBB organization must
receive the form no later than sixty days after the event that creates the special
open enrollment. In addition to the required form, the school employee must provide
evidence of the event that creates the special open enrollment to the SEBB
organization. SEBB medical will begin the first day of the month following the later
of the event date or the date the required form is received. If that day is the first
of the month, coverage is effective on that day. If the special open enrollment is due
to the birth, adoption, or assumption of legal obligation for total or partial support
in anticipation of adoption of a child, SEBB medical will begin for a school employee
on the first day of the month in which the event occurs (see WAC 182-31-150(3)) for
the SEBB medical effective date of a newly born child, newly adopted child, spouse, or
state-registered domestic partner).
(4) Special open enrollment: Any one of the events in (a) through (k) of this
subsection may create a special open enrollment. The change in enrollment must be
allowable under the Internal Revenue Code (IRC) and Treasury regulations, and
correspond to and be consistent with the event that creates the special open
enrollment for the school employee, the school employee's dependent, or both. (a)
School employee acquires a new dependent due to: (i) Marriage or registering for a
state domestic partnership; (ii) Birth, adoption, or when the school employee has
assumed a legal obligation for total or partial support in anticipation of adoption;
or (iii) A child becoming eligible as an extended dependent through legal custody or
legal guardianship. (b) School employee or a school employee's dependent loses other
coverage under a group health plan or through health insurance coverage, as defined by
the Health Insurance Portability and Accountability Act (HIPAA); (c) School employee
has a change in employment status that affects the school employee's eligibility for
their employer contribution toward their employer-based group medical; (d) The school
employee's dependent has a change in their own employment status that affects their
eligibility for the employer contribution under their employer-based group medical;
Note: As used in (d) of this subsection "employer contribution" means contributions
made by the dependent's current or former employer toward health coverage as described
in Treasury Regulation 26 C.F.R. 54.9801-6. (e) School employee or a school employee's
dependent has a change in enrollment under an employer-based group medical plan during
its annual open enrollment that does not align with the SEBB program's annual open
enrollment; (f) School employee's dependent has a change in residence from outside of
the United States to within the United States, or from within the United States to
outside of the United States and that change in residence results in the dependent
losing their health insurance; (g) A court order requires the school employee or any
other individual to provide a health plan for an eligible dependent of the school
employee (a former spouse or former state registered domestic partner is not an
eligible dependent); (h) School employee or a school employee's dependent becomes
entitled to coverage under medicaid or a state children's health insurance program
(CHIP), or the school employee or a school employee's dependent loses eligibility for
coverage under medicaid or CHIP; (i) School employee or a school employee's dependent
becomes eligible for state premium assistance subsidy for SEBB health plan coverage
from medicaid or a state children's health insurance program (CHIP); (j) School
employee or a school employee's dependent becomes eligible and enrolls in a TRICARE
plan, or loses eligibility for a TRICARE plan; (k) School employee becomes eligible
and enrolls in medicare, or loses eligibility for medicare.
[Statutory Authority: RCW 41.05.021, 41.05.160, 2017 3rd sp.s. c 13, 2018 c 260, and
SEBB policy resolutions. WSR 19-14-093 (Admin #2019-01), § 182-31-080, filed 7/1/19,
effective 8/1/19.]
Preliminary Report: School Employees Benefits Board Coverage
October 2021
Recommendations & Responses
Legislative Auditor Recommendation
The Legislative Auditor makes one recommendation regarding ongoing
data collection
Recommendation #1: OSPI and HCA should work with House and Senate fiscal staff to
determine what additional data elements might be needed for ongoing data collection.
If new elements are suggested, OSPI and HCA should each develop a data collection plan
and identify resource requirements as applicable.
The Office of Superintendent of Public Instruction (OSPI) and the Health Care Authority
(HCA) both collect data relevant to this study, but neither agency currently collects
all of the data elements included in this study. Adding elements outlined in section 6
of this report would require more work by the agencies and districts. Prior to
undertaking this effort, the Legislature should consider whether this JLARC staff
report provides sufficient information or whether ongoing monitoring is desired.
By June 30, 2022, OSPI and HCA should report to JLARC on results of discussions
with House and Senate fiscal staff and whether additional data elements are desired
for ongoing data collection.
If new data elements are suggested, then OSPI and HCA should each develop a data
collection plan detailing the actions, costs, and timelines needed to add the
additional data elements to their ongoing data collection efforts. The plans are due
by December 31, 2022.
Legislation Required:
None
Fiscal Impact:
JLARC staff assume the recommended action can be implemented within existing
agency resources. If additional data elements are suggested, OSPI and HCA should
identify fiscal impacts in their data collection plan(s).
Implementation Date:
Initial report to JLARC due by June 30, 2022. If applicable, subsequent agency
data collection plans due by December 31, 2022.
Agency Response:
To be included with Proposed Final Report.
Preliminary Report: School Employees Benefits Board (SEBB) Coverage
October 2021
Recommendations & Responses
Agency Response
Agency response(s) will be included in the proposed final report, planned for January
5, 2022.
Preliminary Report: School Employees Benefits Board (SEBB) Coverage
October 2021
Recommendations & Responses
Current Recommendation Status
JLARC staff follow up with agencies on Legislative Auditor recommendations for 4
years. Responses from agencies on the latest status of implementing recommendations
for this report will be available in 2022.
Preliminary Report: School Employees Benefits Board (SEBB) Coverage
October 2021
More About This Review
Audit Authority
The Joint Legislative Audit and Review Committee (JLARC) works to make state government operations more efficient and effective. The Committee is comprised of an equal number of House members and Senators, Democrats and Republicans.
JLARC's nonpartisan staff auditors, under the direction of the Legislative Auditor,
conduct performance audits, program evaluations, sunset reviews, and other analyses
assigned by the Legislature and the Committee.
The statutory authority for JLARC, established in Chapter 44.28 RCW,
requires the Legislative Auditor to ensure that JLARC studies are conducted in
accordance with Generally Accepted Government Auditing Standards, as applicable to the
scope of the audit. This study was conducted in accordance with those applicable
standards. Those standards require auditors to plan and perform audits to obtain
sufficient, appropriate evidence to provide a reasonable basis for findings and
conclusions based on the audit objectives. The evidence obtained for this JLARC report
provides a reasonable basis for the enclosed findings and conclusions, and any
exceptions to the application of audit standards have been explicitly disclosed in the
body of this report.
Preliminary Report: School Employees' Benefits Board (SEBB) Coverage
October 2021
More About This Review
Study Questions
Click image to view PDF of proposed study questions.
Preliminary Report: School Employees Benefits Board (SEBB) Coverage
October 2021
More About This Review
Methodology
The methodology JLARC staff use when conducting analyses is tailored to the scope of each study, but generally includes the following:
Interviews with stakeholders, agency representatives, and other
relevant organizations or individuals.
Site visits to entities that are under review.
Document reviews, including applicable laws and regulations, agency
policies and procedures pertaining to study objectives, and published reports,
audits or studies on relevant topics.
Data analysis, which may include data collected by agencies and/or
data compiled by JLARC staff. Data collection sometimes involves surveys or focus
groups.
Consultation with experts when warranted. JLARC staff consult with
technical experts when necessary to plan our work, to obtain specialized analysis
from experts in the field, and to verify results.
The methods used in this study were conducted in accordance with Generally Accepted Government Auditing Standards.
More details about specific methods related to individual study objectives are described in the body of the report under the report details tab or in technical appendices.
Preliminary Report: School Employees Benefits Board (SEBB) Coverage
