Recapof TheAffordableCareActandAdjunctFaculty:ACommunityConversation Pittsburgh,PA,March6,2013 SponsoredbytheAdjunctFacultyAssociationoftheUnitedSteelworkers (AFAUSW) Contact:HeatherSteffen,heather.steffen@gmail.com Attendance:20people(abouthalfadjunctfaculty,severaltenuretrackfacultyandgrad students,andanumberofnonuniversityaffiliatedcommunitymembers)+thethree moderators(MariaSomma,UnitedSteelworkersRobinSowards,DuquesneAdjunct FacultyAssociationandHeatherSteffen,AFAUSW) Introduction: MariaSommaopenedthemeetingwithbriefremarksonitsgoalofcollecting communitymembersviewsontheACAandhowitmatterstoadjunctfaculty,and sheemphasizedtheimportanceofmakingourviewsknowntotheIRSasthey collectcommentaryontheACA.

. HeatherSteffengaveabriefoverviewoftheissuestheACAraisesforadjunct faculty(seeAppendixAbelow). RobinSowardsdescribedthemainpointsoftheAFAUSWsdraftcommentstothe IRS(seeAppendixBbelow). Mainpointsofgroupdiscussion: Themajorityofthediscussionfocusedonthenumberofhoursadjunctfacultyspend inpreparationforclass.Intheirdraftcomments,SowardsandSteffenincludedonly 1hourperweekforeachhourintheclassroomforpreparation.Almostall participantsinthisdiscussionfeltthatthiswasfartoolow.Someofthecomments were(notverbatim): Prepisreallymorelike34hoursforeachhourteaching,notincluding grading. Preptimealsoincludeskeepingupwithadvancesinyourdiscipline,so34 hoursseemsmoreaccuratethan1. AnyIRSruleshouldincludespecialconsiderationforlabcoursesbecause theseareoftencreditedandcompensatedas1creditcourses,butthey meetformorelike2.5hoursperweek.Thismeansthecalculationoflab instructorshoursshouldnotbelinkedtocredithours. Isitpossibletogivehistoricaldataonpreptimeatuniversitiesoronhow hourshavebeencalculatedinthepast? AdjunctfacultyhavetoputinmorepreptimethanTTfacultybecausethey maybeaskedtoteachcoursesatthelastminuteortoteachcoursesoutside theirexpertisemoreoften. Alotofprepalsohappensbeforethesemesterbegins,soclaimingthat34 hoursprepperhourofteachingisthenormcouldmakesenseintheIRS

commentsifonenotesthatthenumberincludestimeworkedbeforethe semesterspreadoutoverthesemester(i.e.theperiodofcompensation). Thelackofinfrastructure(offices,computers,accesstocopiers)thatmany adjunctfacultydealwithalsoincreasesthetimespentonteachingbecause theydonothavesomewhereoncampustostoretheirmaterialsora convenientlocationinwhichtomeetwithstudents. Couldwearguethatadjunctfacultyhoursshouldbecalculatedasapercentageof thehoursworkedbyfulltime,tenuretrackfaculty? Mostfeltthatitisjustnotcomparable,becauseTTfacultyteachgraduate andundergraduateclasses,haveoffices,andhavetofocusonresearchand serviceaswellasteaching. Onetenuredfacultymemberpresentnotedthatfourcoursespersemesteris thenormforTTfacultyatresearchuniversities,buttheyusuallyhavetheir loadreducedthroughcoursesreleasesbuiltintotheircontractstocover researchandservicework. Ofthenineadjunctfacultyintheroom,threecovertheirowninsurancenow,andthey allhavedisasteronlycoverage. Whatelsedoesthenumberofhoursyouworkaffect? Eligibilityforfoodstampsandwelfare(irregularpaycheckscanmakeithard togetthisevenifyouqualify),childcare Whoelsemightbeaffectedbytherulesputinplaceforadjunctfaculty? Technicalworkers,contractors,taxidrivers,etc.? Thecoreofthisdebateisfiguringoutwhatconstituteswork.

TopostyourowncommentstotheIRSortoviewcommentsalreadyposted,visit: http://www.regulations.gov/#!docketBrowser;rpp=50;po=0;dct=PS;D=IRS-2013-0001 TheAFThassomeadviceonhowtocommenthere: http://www.aft.org/newspubs/news/2013/030113aca.cfm AppendixA:OverviewofIssuesRaisedforAdjunctFacultybytheAffordableCare ActbyHeatherSteffen TheAffordableCareActisanincrediblycomplexpieceoflegislation,sowereonly goingtohavetimetocoverafewquestionsitraisestonight.Butjusttogeteveryoneon thesamepage,Illtrytoquicklyoverviewthemainissuesadjunctfacultymightfacewhen theACAgoesintoeffectin2014. Asyouprobablyknow,thegoaloftheAffordableCareActistoprovideaccessto affordablehealthinsuranceandhealthcaretoallAmericans.Onewayittriestodothisis byrequiringthatanybusinessororganizationthatemploysmorethan50fulltimeworkers mustofferthemaccesstoinsurance(thoughitdoesntrequirethattheemployerpayfor thatinsurance). Ifanindividualwhoisnotcoveredbyanemployersponsoredhealthplandoesnot obtaininsurance,heorshewillhavetopayapenalty.Butthosewithout

employersponsoredcoveragewillbeabletobuyaffordableinsuranceonsubsidized healthcareexchangeswithaslidingscaleofcosts.Ontheflipside,ifalargeemployer (withmorethan50workers)doesnotprovideinsuranceforatleast95%ofitsworkforce,it mustpaya$2,000penaltyforeachuninsuredemployee,aswellaslosingoutonalotof lucrativetaxbreaks.Thepenaltiesaremeanttoincentivizeemployerstoofferhealthcare coverage. TheissuestheAffordableCareActraisesforadjunctfaculty,however,stemfrom thefactthattheActdefinesfulltimeas30hoursofworkperweek.Butadjunctsworking timeisntcalculatedbythehour.Itsmeasuredbythecourse.SotheIRSiscollecting commentstotrytodetermineareasonablestandardformeasuringteacherstime commitmentsforthepurposesoffiguringoutwhetheracollegeoruniversityshouldbe penalizedifitfailstoofferhealthcoverage.ThusthesimplestproblemtheAffordableCare Actraisesforadjunctfacultyishowtomeasuretheirworkingtime,andIhopewellheara lotfromtheteachersheretodayabouthowtheyestimatetheirownworkinghours. IntheweekssincetheIRScalledforcomments,however,anumberofmore complexproblemshavecomeupindiscussionsaboutadjunctsandtheAffordableCare Act.Thedebateseemstosplitbetweengroupsadvocatingsolutionsfortheshorttermand thoselookingtothelongerterm. ThoseconcernedprimarilywiththeproblemstheACAcouldcauseforadjunct facultyintheshorttermhaveacompellingargumentbecauseitseemsthatcollegesare alreadytryingtofindwaystogetaroundtheActsprovisions.CCACandanumberof otherschoolsaroundthecountryhaveannouncedthisyearthattheywilllimitthenumberof coursestheiradjunctfacultycanteachinordertoavoidhavingtheiremployeesclassified asfulltimeworkers.Theshorttermcampsargumentisthusthatadjunctfacultyshouldtell theIRSthatteachingtakesaminimalamountoftimesothattheycanmaintainheavy courseloadsandmakeabasiclivinginagrosslyundercompensatedlineofwork. Ontheotherhand,thelongtermcampworriesthatifadjunctfacultydontexplainthe fullextentoftheirteachingrelatedtimecommitments,itwillbeimpossibletoarguelaterfor normalization,jobsecurity,orhigherpayincollectivebargainingorothereffortstoimprove laborconditions.Thelongtermcampthusarguesforfullreportingofteachersworking hours,inspiteofthechanceofhavingtheirworkloadsforciblyreduced. Thisseemstobethebasicsplitatpresent,butsomeareraisinganevenmore worrisomepossibility,whichisthatcollegesanduniversitiesmightexploitanapparent loopholeintheAffordableCareActbydefiningadjunctfacultyasfulltimeforthepurposes oftheAct,butthenofferingonlysubstandardandpotentiallyexpensivehealthplansto avoidthepenalty.Thiswouldmakeitimpossibleforadjunctfacultytooptintothe affordableandpossiblyhigherqualitysubsidizedplansofferedontheexchanges.The AffordableCareActpresentsalotoffurtherquestionsforadjunctfacultythatarerelatedto studentloanforgiveness,welfareeligibility,andothergovernmentprogramsandthatIm surewillbebroughtupthisevening,butwedratherhearwhatyouallhavetosayabout them,soIllstophereandletRobintakeover. AppendixB:RobinSowardsandHeatherSteffensDraftCommentstotheIRS A PROPOSAL FOR CALCULATING ADJUNCT FACULTY HOURS FOR THE PURPOSES OF THE IMPLEMENTATION OF THE

PATIENT PROTECTION AND AFFORDABLE CARE ACT OF 2010 BY THE UNITED STATES DEPARTMENT OF THE TREASURY AND INTERNAL REVENUE SERVICE I.INTRODUCTION TheFederalRegisterof2January2013(78F.R.218)indicatedthat[t]heTreasury DepartmentandtheIRSarecontinuingtoconsider,andinvitefurthercommenton,how besttodeterminethefulltimestatusofadjunctfacultymembersforthepurposesof SharedResponsibilityforEmployersRegardingHealthCoverage.1 Thisdocument proposesaspecificformulaformakingsuchadetermination. II.COMMENTATORSBACKGROUND&CONTACTINFORMATION Background: Robin J. Sowards earned his Ph.D. in English Literature from Cornell University, and is currently an adjunct faculty member in the Department of English at Duquesne University in Pittsburgh, where he teaches firstyear writing, literature, and linguistics. Dr. Sowards is also a member of the volunteer organizing committeeoftheAdjunctFacultyAssociationoftheUnitedSteelworkers. Heather Steffen is a Ph.D. Candidate in Literaryand CulturalStudies at Carnegie Mellon University, where she teaches courses on firstyear writing, literature, and contemporaryissuesinhighereducationasagraduateinstructor.Shehasauthored a number of articles and papers on United States academic labor and its history, and she currently works for the Adjunct Faculty Association of the United Steelworkers. ContactInformation: Robin J. Sowards can be reached at the Adjunct Faculty Association, United Steelworkers,Five Gateway Center,Pittsburgh, PA15222tel.: 412.562.2451fax: 412.562.2429email:rsowards@usw.org. Heather Steffen can be reached at the Department of English, Carnegie Mellon University,Pittsburgh,PA15213email:heather.steffen@gmail.com. III.CONTEXTANDPROPOSAL
1. Adjuncts and the Purpose of a University. Universities exist primarily2

to carryout

two purposes: (1)research, thepursuitof truth foritsown sake3

1 2

and(2) teach

I.R.C.4980H. Public and many private institutions of higher education also have a missionofservicetotheircommunityandto theeducation ofglobalcitizens.Religiouslyaffiliatedinstitutions,insomecases,addamissiontopropagateaparticularsetofreligiousbeliefs. 3 The researchmissionofuniversitiesbenefitssocietyas awhole bycultivatinginnovation.Butinnovationcan onlybecultivated if it is free from external interference, whetherfromgovernment, business,orprivatecitizens. Consequently,research canonly benefit society if it is not required by any third party to benefit society, sincedoingsowould hinderinnovation.Forthisreason, the research mission of a university mustbeunderstoodasseekingtruthforitsown sake, or,to usethe more traditionalidiom, itspursuitoftruthmustbedisinterested(i.e.,unconstrainedbyanyinterestinaparticularconclusion).

dissemination of (a)the methods ofresearch andtheskillsoftrades and professions, and (b) the existing bodies of knowledge in research, trades, and professions. Traditionally,thetermcollegereferstoaninstitutionofhighereducationwhosepurpose isteaching only.4 In general, at 6 teaching. 2. Variations in Adjunct Hours. The amount of time adjunct faculty spend teaching, however, can vary considerably, both from one department to the next and within a single department. This variation can be obscured somewhat by the fact thatcourses that take considerably more time to teach may officially provide the same number of credit hoursascoursesthattakelesstimetoteach.(Todaycredit hoursarenormally usedto quantify studentlearning, thoughthey wereoriginallyinventedtoquantifyfaculty workload.)Noequitableformulaforcalculatingadjuncthourscanignorethisvariation. 3. Sources of Variation. Consequently, a formula for calculating adjunct hours for the purposes of the Patient Protection and Affordable Care Act of 2010 (PPACA) must take into account the differences in time commitment between courses. Any adjunct teachingacoursespendstimeinthefollowingthreemainareas: a. Preparation,including i. Course administration (making institutional arrangements for the course, e.g., ensuring appropriate classroom space or ordering textbooks in the university bookstore) ii. Course design (constructing the content, assignment structure, schedule, and policiesofthecourse) iii. Assignment design (constructing the specific assignments students will complete)and iv. Lessonplanning(constructingthecontentofclassmeetings) b. Instruction,including i. Class meetings (time spent in the classroom or lab with all or some enrolled students)
4

The names that institutions of higher education in the United States givethemselves thesedays donotconsistently reflect this distinction between universities and colleges. Many liberal arts colleges, for example, require substantial research productivity of their tenurestream faculty, and some institutions call themselves universities without any substantial commitment to supportingtheresearchagendasoftheirfaculty. 5 For the purposes of this document, the term adjunct faculty is intendedtoincludeallhighereducationinstructionalpersonnel who are neither graduate students nor faculty occupying traditional tenurestream appointments. Most adjunct faculty in the United Statesareemployed onanofficiallyparttime basis,eventhoughthey carryoutthe majorityofhighereducation instruction (see http://www.academicworkforce.org/Research_reports.html). Neither institutions of higher education nor participants in public discourse are consistent in their use of terminology, and adjunct faculty are therefore referred to by many job titles, including adjunct professor, visiting assistant professor, instructor, lecturer, contingent faculty,adhocfaculty,andsessionalfaculty,amongmanyothers. 6 In the natural sciences, universities frequently employresearchonlypersonnel,butthoseemployeesarenotusually classified or remunerated as adjunct faculty. Some professional schools in professions suchas nursing alsoemployclinical personnel who are sometimes categorized as adjunct faculty even if they do not engage in classroom teaching. It would bedesirable for colleges and universities to adopt clearer distinctions between these employment categories, since they are clearly quite differentkinds of work.Forexample,theUniversity ofMissouris ExecutiveGuideline Number 35 usefullydistinguishes between Research faculty, Teaching faculty, Clinical/Professional Practice faculty, Extension faculty, and Librarian faculty (http://www.umsystem.edu/ums/rules/collected_rules/faculty/ch310/310.035_non-tenu

re_track_faculty).Similarlytransparentmodelsshouldbeadoptedelsewhere.

ii. Officehours(time spent inalocationpublicizedto studentsforstudentmeetings

ortutoring)and
iii. Communication with students7

(email, telep

outsideofofficehours,ormaintenanceofacoursewebsite) c. Assessment,including i. Homework (problem sets, informal writing, online discussion forums, quizzes, etc.) ii. Exams(writtenand/ororal)and iii. Formalwriting(essays,labreports,researchprojects). 4. Similarities between Courses.Despitethediversityofcoursetypestaughtbyadjunct faculty members, some facets of teaching practice and time commitment are comparable across all courses. Assuming a hypothetical faculty member who is relatively experienced, has taught the course in question previously,8 spendstheti 9 thatis necessary to teachtheclassatareasonablelevelofacademicexcellence, and isreasonablyefficientinthemanagementofhisorhertime,theratioofcontacthoursin class to preparation hours will remain essentially constant across different courses. Typically, for a single course there will be three class meetings per week of approximatelyone hour each. It seems reasonabletosupposethateachofthosethree contact hours will require an equal amount of preparation time (i.e., one hour of preparation for each contact hour). (At many institutions, one additional hourofoffice hours is required for every three hours of class meetings, but office hours do not normallyrequireadvancepreparation.) 5. A Formula for Adjunct Faculty Hours. The main source of variation between different courses is thus located in assessment. A formula for calculating adjunct facultys percourse working hours for the purposes of determining whether anadjunct faculty member is a fulltime employee under section 4980H of the PPACA should therefore distinguishcoursesin which assessment is moretimeconsumingfromthose in which it is less timeconsuming. The determination of which coursesaremore and less timeconsuming shouldfall to thefacultymembers whoteach the course and their immediate supervisors, since onlythey haveaccess tosufficient information to render thatdetermination.Wemightcalculatethehourspercourseperweekasfollows: a. Instruction: total hours ofclass meetings per week(roundedto the hour)+ 1 office hourpercourseperweek+1hourofcommunicationpercourseperweek
7

In earlier periods, students who wished to communicate with their instructors outside of class did so by making use of their office hours. Today, although faculty are still required to hold office hours to the same extent, faculty are also expected to be accessible to student communication at essentially all times via email, chat, telephone, or the like. This expectation puts even adjunctfacultyessentiallyoncallallday,everyday. 8 A course one hasnt taught previously will often require considerably morepreparation, bothatthe levelofcoursedesignand at the level of individual lesson planning. Since this extra time will only be spent the first time one teaches the course, for the purposes of these calculations, were assuming a hypothetical faculty member who hastaughtthecourseatleast oncebefore andthusisinthepositionofrefininghisorherapproachtothematerialratherthancreatingitwholecloth. 9 Doing so requires providing accurate, uptodate, and challenging course content, as well as providing students with regular feedback on their performance and maintaining consistent high academic standards, all of which requires a considerable commitment of time. See http://www.liberalarts.wabash.edu/study-research/ foradetailedstudyofwhat practices maximize student learning outcomes in higher education, including Good Teaching and HighQuality Interactions with Faculty, Academic Challenge and High Expectations, and Diversity Experiences (Overview of Findings from the First Year of theWabashNationalStudyofLiberalArtsEducation,p.7).

b. Preparation:1hourofpreparationforevery1hourofclassmeetings c. Assessmentvariesbycourse,asfollows: i. LightAssessment:1hourofassessmentforevery1hourofclassmeetings ii. Medium Assessment: 1.5 hours of assessment for every 1 hour of class

meetings iii. HeavyAssessment:2hoursofassessmentforevery1hourofclassmeetings 6. Assessment Weight.Manycriteriacan determinewhatmakesthelevelofassessment in a course light, medium,orheavy,andthefaculty members discretionshould bethe ultimatearbiter.Thereare,however,threecriteriathatimmediatelypresentthemselves. a. Class Size: Courses with more students enrolled will take more time to assess (assuming that the faculty member is not provided with substantial assessment supportintheformofteachingassistantsorgraders). b. Class Type: It is typically the casethatcourseswith light assessmentfocus more onthe contentofresearch(presentingknowledgeandinformation thathavealready been established in a particular field) than on the methods of research or on professional or vocationalskills.Courses thatfocus on methods orskills,in which students learn how to conduct research in a particular field or how to perform professional or jobrelated tasks, almost always also teach content, since one cannot learn to think or work without having something to think about or work on. Moreover, to teach methodsor skillsonemustassessboththestudentsmasteryof content and their mastery of the methods or skills, the latter of which involve especially detailed examination or observation of the students work. The task of assessing a students mastery ofmethodsorskillsisrarelyamenabletoanykindof automation, unlike assessing content, which can sometimes be done with multiplechoice exams. Consequently, methods and skills courses frequently have heavierassessmentburdensthancontentonlycourses. c. Assessment Style: All courses rely on summative assessment methods to evaluate the students level of mastery and assign a final grade in thecourse. But some courses also use formative assessments togive studentsfeedbackon their performanceand guidethemtowardimprovement.Formativeassessmentisalmost always more timeconsuming than summative assessment. Therefore, courses involving substantial formative assessment will haveaheavier assessmentburden thanthoseinvolvingonly(orprimarily)summativeassessment. 7. Course Examples. Here, then, are some examples of courses thatmeet thecriteria above: a. LightAssessment: i. Alarge (150 or more students)lecturecoursein Chemistrywhose assignments consist of problem sets and exams (the labs for which would be calculated as separatecoursesforthepurposesoftheformulaproposedhere10). ii. A large (100 or more students) lecturebased English literature survey whose
10

The rationale for doing so is that labs (or discussion sections for large lecture courses in the socialsciencesor humanities) are often taught by someone other than the faculty member who gives the lectures. The hours for those labs, then, will often need to count towardssomeotherpersons workload.Afacultymemberwhoteachesboththe lecture portionof thecourseand a lab section would therefore count as teaching two separate coursesforthepurposesof these calculations.From acurricular pointofview,ofcourse,thesearejustseparateconstituentsofthesamecourse.

assignmentsconsistof reading quizzesand exams (the discussionsectionsfor which would be calculatedas separatecoursesfor thepurposes ofthe formula proposedhere). b. MediumAssessment: i. A small (around 30 students) discussionbased Introduction to Literature courses for nonmajors whose assignments consist of formal writing assignmentsbutnotgradeddrafts. ii. A small (around 25 students) mixed discussion and lecturebased American History course for majors whose assignments consist of formal writing assignmentsbutnotgradeddrafts. iii. A small (around 15 students) graduate seminar whose assignments consistof readings, discussion, and one long research paper due at the end of the semester. c. HeavyAssessment: i. A mediumsized (2025 students) firstyear writing (or composition) course whose assignments consist of formal writing assignments with multiple, assesseddraftsandindividualstudentconferences. ii. A small (1520 students) servicelearning course in professional writing for nonprofit organizations whose assignments consist of collaboration with an offcampusorganizationtocreateacampaign. iii. A small (1520 students) research methodscoursein environmentalscience or in anthropology whose assignments include completion of fieldwork in an offcampuslocation. iv. A small (2025 students) Englishasasecondlanguage or developmental writing course whose assignments consist of many short, formal writing assignments with multiple, assessed drafts and individual student conferences ortutoring. 8. Sample Calculation 1 (Full-time Adjunct with 3/3 Course Load11 ). Suppose Adjunct Faculty Member A teaches two sections of firstyear writing as well as one sectionof a survey of early Englishliteraturefor nonmajors. Suppose furtherthateach course involves three hours of class meetings per week. Since two of those three courses are identical, those two courses will not require separate preparation. So AdjunctFacultyMemberAstotalweeklyhourswouldbecalculatedasfollows: a. Instruction:9(classmtgs.)+3(officehours)+3(communication)=15hours b. Preparation:3(writingcourses)+3(surveycourse)=6hours c. Assessment:92(writingcourses)+31=18+3=21 d. TOTAL:15+6+21=42hoursperweek 9. Sample Calculation 2 (Part-time Adjunct with 2/2 Course Load).SupposeAdjunct Faculty Member B only teaches two sections of firstyear writing and nothing else. Again, those two sections will only require one unit of preparation between them. So AdjunctFacultyMemberBstotalweeklyhourswouldbecalculatedasfollows:
11

In higher education, having a 3/3courseload means thatoneteachesthreecourseseachsemester fortwosemesters(one academic year), thus teaching six courses total per year. Similarly, a 2/2 course load indicates teaching two courses per semesterforoneacademicyear,thusfourcoursestotal.

Instruction:6(classmtgs.)+2(officehours)+2(communication)=10hours Preparation:3hours Assessment:82=16hours TOTAL:10+3+16=29hoursperweek 10. Sample Calculation 3 (Tenure-stream Research Faculty with 2/2 Course Load). Asapoint ofcomparison,TenurestreamResearch FacultyMemberCmightteachthe normal research course load of two courses per semester, one of which is usually a mediumassessment course (such as a graduate seminar) and the other of which is usually a lightassessment course (such as a large lecture). Tenurestream Research FacultyMemberCstotalweeklyhourswouldbecalculatedasfollows: a. Instruction:6(classmtgs.)+2(officehours)+2(communication)=10hours b. Preparation:3(survey)+3(seminar)=6hours c. Assessment:31(survey)+31.5(seminar)=3+4.5=7.5hours d. TEACHINGTOTAL:10+6+7.5=23.5hoursperweek i. Fulltime higher education faculty in the U.S. spend, on average, 58% of their time on teaching,12 so the rema service: e. RESEARCH&SERVICETOTAL:17hoursperweek f. COMBINEDTOTAL:40.5hoursperweek 11. Sample Calculation 4 (Full-time Adjunct with 5/5 Course Load).Afulltimeadjunct faculty member teaching a very high course load, Adjunct Faculty Member D, might havefivesections offirstyearwriting.13 Since they ar not requireadditionalpreparation.If,say,allfivecoursesweredifferent,thecourseload would simply be unmanageable (while also maintaining reasonable academic standards), since the faculty member would be working 70 hours per week.14 So AdjunctFacultyMemberDstotalweeklyhourswouldbecalculatedasfollows: a. Instruction:15(classmtgs.)+5(officehours)+5(communication)=25hours b. Preparation:3hours c. Assessment:152=30hours d. TOTAL:25+3+30=58hoursperweek
a. b. c. d.

IV.CONCLUSIONS Theproposalsetforthaboveisslightlymorecomplexthanothercommonlyusedmethods forcalculatingfacultyworkinghours(suchassimplydoublingthecredithours).Itdoes,

12 13

http://nces.ed.gov/programs/digest/d11/ch_3.asp

While this may seem like an extremely heavy course load, teaching 5/5 is notuncommon foradjunctinstructors atcommunity colleges and many public institutions. Many adjunct instructors also teach five or more courses per semester across multiple institutions in order to earn a living bycobblingtogether multiple parttimecontracts. Severaladjunctfacultymembersthatweare acquainted with teach as many as eight courses every semester, so that their total income stays at least a little bit above the povertyline. 14 One indicationthat working this many hoursperweek is excessiveisthatextended work hours(morethan60 orsohours per week) are strongly correlated with an increase in industrial worker injuries and fatalities. See, for example, http://www.ncbi.nlm.nih.gov/pubmed/17594716, a study which found that Workers who worked more than64hrintheweekbeforetheshifthadan88%excessriskcomparedtothosewhoworked40hrorfewer.

however,haveseveraladvantages:
1. Accuracy. It gives a more accurate picture of the actualhoursthat adjunct faculty

work
2. Spirit of the Law. It encourages institutions of higher education to cleave to the

spirit of the PPACA and provide health insurance to a workforce whose remunerationisnotoriouslylow
3. Incentive for Employers. It creates a financial incentive for institutions of higher

education to allocate institutional resources to laborintensive core courses that teachthefoundationalskillsthataremostimportanttoemployersand

4. Incentive for Employees. It creates an incentive for talented faculty to focus

energy and attention on core courses, thus increasing educational quality and the valuethatstudentsreceiveinexchangefortheirtuitionpayments. 10March2013 Respectfullysubmitted, RobinJ.Sowards,Ph.D. HeatherSteffen