Medical Coverage Under The Affordable Care Act (ACA)

Eligibility Process and Frequently Asked Questions

In order to comply with the Affordable Care Act (ACA), Disney offers basic health care coverage to eligible “non-full-time” (regular part time and temp/recurring) employees and Cast Members working in U.S. based locations.

Eligibility (for all locations other than Hawaii) is defined as working for an average of at least 30 hours per week using a 12-month look-back measurement period (or at least 1,560 hours paid for a full 52 weeks).

Non-full-time employees in Hawaii meet the eligibility requirement under the Hawaii Prepaid Health Care Act if they are regularly scheduled to work 20 or more hours per week for four consecutive weeks.

Potentially eligible employees and Cast Members include any non-full-time employee (outside Hawaii) whose hours are regularly scheduled less than the standard 30 hours per week

Non-full-time employees and Cast Members who are covered by a multi-employer union plan/trust fund are excluded since the Company contributes to the employer plan on behalf of the employee (see related FAQ).

All employees and Cast Members who meet the eligibility requirements will receive a benefit enrollment kit mailed to their registered address in SAP at the time of mailing. The kit includes instructions to enroll or decline coverage, and to enroll any eligible dependents. Employees outside Hawaii are eligible to enroll in the Consumer Choice medical plan option, which comes with a Health Savings Account (HSA). There is no employer contribution to the HSA. If the employee does not make an active election to enroll or decline coverage by choosing “No Coverage Medical” by the enrollment deadline date shown on the Personal Fact Sheet included in the enrollment kit, they will be enrolled in individual coverage and weekly payroll contributions will commence with the first paycheck after their effective date of coverage.

If the employee lives in Hawaii, they will be eligible for HMSA Health Plan Hawaii, with a Health Reimbursement Account (HRA). They will be enrolled in individual coverage unless they decline coverage and submit an HC-5 form by their enrollment deadline. There is no cost for coverage for the employee or any dependents they wish to cover.

Effective July 1, 2024, Student Program (College Program or Intern Program) participants will no longer be automatically eligible for ACA coverage upon extension of their program. Student Program participants will be evaluated on their first-year anniversary and, if applicable, annually thereafter.

Employees with questions concerning their eligibility for health care coverage should call the Disney Benefits Center at 1-800-354-3970.

ELIGIBILITY PROCESS

Measurement Period

  • How initial eligibility is determined (employees outside Hawaii)
    If a newly hired employee or Cast Member has a full year of service without a break of greater than 91 days and works at least 1,560 hours during the 12-month period ending on their anniversary date, (“initial measurement period”), he or she will be sent an enrollment packet by the Disney Benefits Center. The employee will then have a 30-day period in which to enroll or decline coverage. They will be assigned coverage if they make no election.

  • If the 1,560 hours requirement is not met during the first year
    After the first year, there will be an ongoing 12-month measurement period from October 6 of the prior year to October 5 of the current year. If they meet the hours requirement during one of these “ongoing measurement periods,” their coverage would be effective the following January.

    NOTE: The hours monitoring report that Cast Members or employees can access should not be used to track ACA hours worked.

Stability Period

  • When coverage takes effect (following initial measurement)
    Coverage will begin effective the last day of the month following the month of the employee’s first year anniversary as long as the employee has met the 1,560-hour requirement (or 20 hour/4-week requirement in Hawaii).

    For example, if an employee was hired on February 15, 2024, and worked at least 1,560 hours as of February 15, 2025, coverage would begin effective March 31, 2025. This begins a 12-month “Stability Period” during which the employee is guaranteed to remain eligible for medical coverage whether or not they have a reduction in hours, end a project, or go on a leave of absence, as long as they remain employed with the Company.

 
FREQUENTLY ASKED QUESTIONS

Click on a link below to jump directly to a topic.

Hours Measurement and ACA Eligibility
New Hire Testing and Eligibility
Rehired Cast Members
Changes in Status
Salaried Exempt Regular Part Time
Leave of Absence (LOA)
Hawaii Employees and Cast Members
Other (International sites; Non-Employees; Multi-Employer Union Plans/Trust Fund)
Health Care Notification and Coverage Details

Hours Measurement and ACA Eligibility

Q1: What is the health care regulation?
A: The Affordable Care Act (or ACA) requires employers to provide affordable health care to all eligible employees who regularly work 30 or more hours per week using the defined look-back period (October 6 of the prior year to October 5 of the current year).

Q2: What hours are measured for 30 hours per week?
A: For all non-full-time employees and Cast Members, working and paid in the United States, ACA hours testing will be implemented by either the initial measurement/new hire process or by the ongoing process; both processes are based on the individual’s hire date. All hours worked for each individual non-full-time employee are considered for ACA measurement which includes hours worked, vacation pay, sick leave, holiday, bereavement leave and jury duty. In addition, regardless of prior status, all ACA eligible hours worked are included for the individual employee during the 12-month look-back period.

Q3: What is the difference between hours worked and hours paid?
A: Hours worked reflect the actual time an employee is working for the company. Hours paid reflect the rate of pay associated with each hour worked. For example, an employee might work 6 hours of overtime at a rate of 1.5X. As a result, their hours worked is 6 and their hours paid is 9. The hours monitoring report reflects hours paid, not necessarily actual hours worked, and therefore does not necessarily reflect eligible ACA hours.

Q4: What is the measurement and eligibility process for ongoing employees and Cast Members?
A: Ongoing employees outside Hawaii who are employed more than one year will be hours evaluated during the annual measurement period, which takes place from October 6 of the prior year through October 5 of the current year. If they meet the ACA hours requirement (at least 1,560 or more hours worked) during the 12-month period, they will be eligible for Consumer Choice and HSA without the Company contribution, and their coverage would be effective the following January for that calendar year (from Jan. 1 to Dec. 31).

For employees in Hawaii, hours are tracked on a weekly basis to determine if the 20 hours/week for four consecutive weeks requirement is met. If so, they will be eligible for HMSA Health Plan Hawaii with HRA. Employees of the Ala Moana Disney Store will have coverage for up to 12 months. Employees of the Aulani Resort receive coverage for 15 weeks. Hours worked will be monitored at the end of the 15-week period, and if the 20 hours/four-week requirement has been met, coverage will continue.

Q5: What medical benefits do employees receive who have worked at least 1,560 hours?
A: Eligible regular and salaried non-full-time employees and Cast Members, who meet the ACA eligibility requirements, receive a health care enrollment kit mailed to their registered address that outlines Consumer Choice and HSA without the Company contribution (or HMSA Health Plan Hawaii with HRA, in Hawaii) and including instructions to enroll or decline coverage and to enroll any eligible dependents. (See additional “Health Care Notification and Coverage Details”)

Q6: What if an employee does not take any action on the enrollment kit they receive?
A: Employees will be automatically enrolled in individual coverage in Consumer Choice, administered by Cigna. Should the employee want to change this coverage, including No Coverage Medical, he or she will need to go online or contact the Disney Benefits Center at 1-800-354-3970 within their stated enrollment period. If an employee takes no action, they will be automatically enrolled and weekly payroll deductions for this coverage will begin with the first paycheck following their effective date.

New Hire Evaluation and Eligibility – outside Hawaii (See related FAQ for details for Hawaii employees and Cast Members)

Q7: How are newly hired employees evaluated for ACA eligibility?
A: For new non-full-time employees and Cast Members outside Hawaii hired after early October, hours worked will be initially measured at the individual’s one-year anniversary date from date of hire. For anyone with at least 1,560 hours worked, they will remain in their current non-full-time status and will be offered Consumer Choice and HSA without the Company contribution. Coverage will be in place for one year starting on the last day of the next calendar month.

For example, if a new hire starts on Jan. 14, 2024, hours paid are measured on Jan. 14, 2025. If the employee has been paid at least 1,560 hours, they will be offered Consumer Choice with HSA without the Company contribution. Coverage will be effective for one year starting Feb. 28, 2024, through Feb. 27, 2025.

Q8: When are newly hired employees and Cast Members monitored in the annual October measurement period as an ongoing non-full-time employee?
A: Newly hired employees will transition to the ongoing process (annual October standard measurement period) after they have been employed at least one full year.

For example, a new hire started on Jan 14, 2024, and hours were measured at the one-year anniversary date on Jan. 14, 2025. In October 2025, they will again have their ACA hours measured with all ongoing non-full-time employees for the prior 12-month look-back period. If hours worked during that period are at least 1,560, the employee will be eligible to continue coverage under the ACA-compliant plan effective the following January for the entire calendar year (Jan. 1, 2026, to Dec. 31, 2026).

Q9: How long does coverage last?
A: If the non-full-time employee continues to meet the 1,560-hour requirement during subsequent ongoing measurement periods, their 12-month “Stability Period” will be on a calendar year basis and enrollment will align with the Annual Benefits Enrollment for active full-time employees.

Q10: When does medical coverage end for the newly hired employee or Cast Member who met the initial anniversary year requirement but does not have at least 1,560 hours in October when they are measured as an ongoing non-full-time employee?
A: If the employee (outside Hawaii) does not meet the 1,560-hour requirement during subsequent ongoing measurement periods, coverage ends after one year based on the calculated end date. The employee will then be offered the opportunity to continue Consumer Choice coverage through COBRA (at the employee’s expense) after the ACA coverage terminates.

For example, if the non-full-time employee is eligible for one year of coverage ending Feb. 28, 2026, and does not have at least 1,560 hours when measured in the ongoing annual October 2025 standard measurement process, coverage ends on Feb. 28, 2026. He or she will then be offered the opportunity to continue Consumer Choice coverage through COBRA effective Feb. 28, 2026, at the employee’s expense after the ACA coverage terminates.

Q11: What happens if the employee leaves the Company?
A: The employee will lose their eligibility for ACA coverage as of the separation date but will be offered the opportunity to continue Consumer Choice or HMSA coverage through COBRA.

Rehired Cast Members

Q12: When are non-full-time rehires considered new hires?
A: Hours testing for non-full-time rehires will be based on the length of break of service after separation from employment:

  • If the break in service is greater than 13 weeks (92 days or more), then the rehire is considered a new hire and ACA hours are measured at the one-year anniversary date from date of rehire.
  • If the break in service is less than or equal to 13 weeks (91 days or less), then the rehire is considered an ongoing Cast Member and ACA hours measured in the ongoing annual October measurement process, and all prior hours paid during the 12-month look-back period are counted.

Q13: Is the non-full-time rehire eligible for benefits if they were in a prior Regular Full Time status?
A: If the rehired employee was in a regular full-time status at time of separation, and is rehired as a non-full-time employee within 14 weeks (91 days), the employee, upon rehire date, will be eligible to enroll in, change or drop their medical coverage (or HMSA, in Hawaii) for the balance of the calendar year. If no action is taken, the employee will receive the same medical coverage that they were enrolled in when their prior employment ended. Dental and vision coverage may be continued through COBRA, if previously enrolled. Please refer rehired employees to the Disney Benefits Center at 1-800-354-3970 for a review of their individual situation.

Q14: If the rehired employee enrolled in COBRA coverage before returning to the Company, can he or she elect to continue their coverage through COBRA?
A: Yes, as long as they continue to pay the required contributions for coverage (for as long as they remain eligible for COBRA).

Changes in Status

Q15: Will non-full-time employees and Cast Members be offered conversion to regular full-time status if they have at least 1,560 or more hours?
A: No. Any job status changes should be discussed with your Leader.

Q16: If a regular full time employee or Cast Member changes status to non-full-time, do they lose all full time benefits?
A: When a full time employee changes status to non-full-time, and if the individual was enrolled in a Disney benefit plan, they will receive a letter from the Disney Benefits Center. Medical Continuation Coverage and employee payroll contributions will automatically continue through the end of the calendar year (December 31). If the employee wants to change this coverage, including a change to No Coverage-Medical, they will need to contact the Disney Benefits Center at 1-800-354-3970 within their stated enrollment period. All other coverage (such as dental, vision and life insurance) will stop, and the employee will receive an option to continue certain coverage through conversion or COBRA.

Q17: If a full-time employee or Cast Member changes status to non-full-time, are prior hours of service in the full time status included?
A: Yes. All hours of service during the 12-month look-back measurement period for non-full-time employees will be included regardless of prior status. The individual’s hours worked will be evaluated in the ongoing annual October standard measurement period, as indicated above. The non-full-time employee may continue to be eligible for medical coverage until hours measured drop below the 1,560 hours threshold.

Q18: If a regular non-full-time employee or Cast Member converts to full-time status for a temporary special assignment, what benefits are offered?
A: As a full-time employee, they will be eligible for full-time Signature benefits based on their job for the duration of the full-time work assignment. If hourly, the employee will receive an enrollment kit from the Disney Benefits Center mailed to the address in SAP at the time of mailing. If salaried, the employee will receive an email with a link to the enrollment information.

Q19: If a non-full-time employee or Cast Member was temporarily statused as full-time due to a temporary assignment, do they lose benefits when they convert back to non-full-time status?
A: When a full time employee changes status to non-full-time, and if the individual was enrolled in Disney benefits coverage, he or she will receive a letter from the Disney Benefits Center. Medical coverage and weekly payroll contributions will automatically continue through the end of the calendar year (December 31). Should the employee want to change this coverage, including No Coverage Medical, he or she will need to go online or contact the Disney Benefits Center at 1-800-354-3970 within their stated enrollment period. All other coverage (such as dental, vision, and life insurance) will stop, and the employee will receive an option to continue certain coverage through conversion or COBRA.

Q20: If a non-full-time employee or Cast Member was temporarily statused to full-time due to a temporary assignment, are prior hours of service in the full time status included?
A: Yes. All hours of service, regardless of prior status, will be evaluated during the ongoing annual October measurement period. The non-full-time employee may continue to be eligible for medical coverage unless their hours drop below the 1,560 hours threshold when measured.

Q21: What happens to coverage when a non-full-time employee or Cast Member with the ACA health care coverage changes to full-time status?
A: If the employee changes status to full-time, they will be offered the opportunity to enroll in full Signature benefits, including all medical plan options. If hourly, the employee will receive an enrollment kit from the Disney Benefits Center mailed to their registered address in SAP at the time of mailing. If salaried, the employee will receive an email with a link to enrollment information.

Salaried Exempt Regular Part Time

Q22: How are hours measured for Salaried Exempt non-full-time employees and Cast Members?
A: To receive credit for actual hours worked for ACA eligibility, Salaried Exempt non-full-time employees should enter their weekly actual hours worked into their business unit’s time recording system (i.e. CATS or Kronos). These hours would be considered for ACA measurement purposes only and will not impact hours paid. PLEASE NOTE: When an employee enters their actual hours worked on a weekly basis, they must accurately reflect the hours for each week. Ongoing employees who are employed more than one year will be measured during the annual October standard measurement period based on the business unit’s time recording system; new hires will be measured at their one-year service anniversary date. In addition, all hours of service during the 12-month look-back period will be included regardless of prior status (such as prior full time hours before converting to the Salaried Exempt non-full-time position).

Leave of Absence (LOA)

Q23: For non-full-time employees and Cast Members who are on an approved Leave of Absence during the 12-month look-back period, are ACA hours adjusted for LOA time?
A: Yes. The Company will evaluate any non-full-time employee with documented LOA time during the 12-month measurement period. The calculation evaluates any employees with hours worked in the range between 1,000 hours to 1,559 hours and determines if there are unreported hours due to documented leaves (Family Medical Leaves (FML), Maternity, Medical, Military and Jury Duty). For documented LOA time, up to 501 maximum hours may be granted for ACA measurement for non-full-time employees during the 12-month measurement period. Personal LOA time is not credited.

Hawaii Employees and Cast Members

Q24: How are Hawaii employees and Cast Members measured for ACA hours requirements?
A: For employees in Hawaii, hours are tracked on a weekly basis in line with the Hawaii Prepaid Healthcare Act to determine if the 20 hours/week for four consecutive weeks requirement is met. If so, they will be eligible for HMSA Health Plan Hawaii with HRA. Employees of the Aulani Resort receive coverage for 15 weeks. Hours worked will be monitored at the end of the 15-week period, and if the 20 hours/four-week requirement has been met, coverage will continue. If the hours requirement has not been met, he or she will be offered the opportunity to continue HMSA Health Plan Hawaii coverage through COBRA at the employee’s expense.

Hawaii non-full-time employees are measured in two different processes:

  • The Company monitors Hawaii employees on a monthly basis as described above to comply with Hawaii state health care law eligibility requirements; and
  • We also measure Hawaii non-full-time employees for ACA hours testing during the
    12-month look-back period in the applicable ongoing process (annual October standard measurement period) or in the new hire process based on hire date.

Q25: What ACA medical plan coverage is offered to Hawaii non-full-time employees and Cast Members?
A: If the employee lives in Hawaii, they will be eligible for HMSA Health Plan Hawaii, with a Health Reimbursement Account (HRA) for any potential wellness rewards. The employee will be enrolled in individual coverage unless they enroll in No Coverage Medical and submit an HC-5 form to the Disney Benefits Center by their enrollment deadline. There is no cost for coverage for the employee or any eligible dependents they wish to cover.

Other (International sites; Non-Employees; Multi-Employer Union Plans/Trust Fund)

Q26: Are International non-full-time employees and Cast Members included in ACA hours testing and eligible for medical benefits?
A: No. International employees are not considered working in the US and therefore are not subject to ACA eligibility requirements.

Q27: If a non-full-time employee or Cast Member transfers from an International work assignment to a US-based position, are any prior hours worked included in the ACA hours testing?
A: No. Any prior hours worked outside the US will not be included when the Cast Member transfers to a non-full-time position in the US; they will be measured as a new hire and ACA hours measured at the one year anniversary date from date of hire into the US-based regular part time or temp/recurring position.

Q28: Are non-full-time employees (such as Independent Contractors, Third Party-Operating Participants, and Vendors) included in the ACA hours testing and eligible for medical benefits?
A: No. Non-employees, regardless of status, are not eligible for benefits from TWDC. Any prior hours worked in a non-Employee assignment will not be included when the individual transfers to non-full-time position with the Company; they will be treated as a new hire and ACA hours measured at the one year anniversary date from date of hire as a Disney employee.

Q29: Are non-full-time employees or Cast Members covered by a multi-employer union plan/trust fund eligible for health care benefits?
A: No. Non-full-time employees and Cast Members who are covered by a multi-employer union plan/trust fund are not monitored for ACA hours and are not eligible for medical benefits. The Company contributes to the employer plan on behalf of the employee. Please contact your union representative if you have any questions.

Health Care Notification and Coverage Details

Q30: How are employees and Cast Members notified that they are eligible for ACA health care coverage?
A: Once the employee meets the eligibility requirement for coverage (see page 1 on eligibility process), eligible employees or cast members will receive an enrollment kit advising that they have qualified to enroll in medical coverage and that they must actively enroll in or decline coverage for themselves and any eligible dependents. If hourly, the employee will receive an enrollment kit from the Disney Benefits Center mailed to the address in SAP at the time of mailing. If salaried, the employee will receive an email with a link to the enrollment information. If the employee does not respond, they will be automatically enrolled in individual coverage.

Q31: What coverage is offered?
A: Employees outside Hawaii are eligible to enroll themselves and their eligible dependents in the Consumer Choice medical plan option, which comes with a Health Savings Account (HSA). There is no employer contribution to the HSA. If the employee does not make an active election to enroll themselves and their dependents, or to select “No Coverage Medical”, they will be automatically enrolled in individual coverage under Consumer Choice and weekly payroll contributions will commence with the first paycheck after their effective date of coverage. Coverage will be for one year based on eligibility (see page 1).

If the employee lives in Hawaii, they will be eligible for HMSA Health Plan Hawaii, with a Health Reimbursement Account (HRA) for any potential wellness rewards. The employee will be enrolled in individual coverage unless they enroll in No Coverage Medical and submit an HC-5 form to the Disney Benefits Center by their enrollment deadline. There is no cost for coverage for the employee or any eligible dependents they wish to cover.

Q32: Can the employee cover dependents?
A: Yes. As with full-time employees eligible for Disney medical coverage, ACA-eligible non-full- time employees can choose to cover eligible dependents including a spouse or domestic partner and children up to age 26. The same active rates will apply for dependent coverage. The employee must enroll their eligible dependents within their stated enrollment window, or if they experience a qualified life event (i.e. marriage, divorce).

Q33: Are non-full-time employees eligible to earn Wellness Rewards?
A: Yes. Any active U.S.-based employee enrolled in a Disney medical plan option is eligible to earn Wellness Rewards. This includes non-full-time employees who are eligible for required ACA coverage under Consumer Choice or HMSA Health Plan Hawaii. If a spouse or domestic partner is also enrolled, they can also earn rewards. Details of the Wellness Rewards Program are available on the D Life | My Benefits site at Benefits.Disney.com. Any wellness rewards earned will be deposited into the employee’s HSA. (If the employee lives in Hawaii, rewards will be deposited into the HRA.)

Q34: Can the employee contribute to the HSA?
A: Yes. The employee may elect to contribute to their HSA through payroll deduction up to the IRS annual limits, less the amount of potential wellness rewards Disney could contribute.

Q35: What other benefits are non-full-time Cast Members eligible for?
A: All Disney employees, including employees and Cast Members who qualify for ACA medical coverage, are eligible for the Employee Assistance Program and Personal Life Resources.

Q36: Is the HSA set up automatically?
A: Yes. Whether the employee actively selects or is automatically enrolled in Consumer Choice coverage, the HSA will be set up automatically. The employee will receive a welcome kit from Optum Financial, the administrator for the account, with additional information and terms and conditions of the account. An Optum Financial debit Mastercard® will be mailed separately to the address on file. The employee can then set up and manage account preferences online at optumbank.com/disney. (If the employee lives in Hawaii, Optum Financial will send an HRA welcome kit and separate mailing with the Optum Financial debit Mastercard® to access wellness rewards credited to the HRA.)

Q37: If an employee or Cast Member was eligible for ACA health care coverage for the full year, what happens if their hours measured in the annual October standard measurement period are under 1,560 hours?
A: If a non-full-time employee or Cast Member was eligible for ACA medical coverage and their hours measured in the annual October measurement period are under 1,560 hours for the12-month look-back measurement period, they will lose eligibility for coverage beginning January 1 of the following calendar year. The employee will be offered the opportunity to continue coverage through COBRA after their coverage ends. For example, if the employee was eligible from Jan. 1, 2024, to Dec. 31, 2024, and their annual hours are under 1,560 in October 2024, they will lose coverage as of January 1, 2025 and will be mailed a COBRA enrollment kit.

Q38: What happens if the employee or Cast Member, who has ACA medical coverage, leaves the Company?
A: Eligibility for ACA coverage will end as of their date of separation from employment from the Company, but the employee will be offered the opportunity to continue coverage through COBRA. If the employee has earned Wellness Rewards or made contributions to the HSA, their account at Optum Financial remains with the employee upon separation and monthly account maintenance fees will apply. If the employee lives in Hawaii, any wellness rewards paid into an HRA account will be available only through the end of the calendar year in which the employee separates, and then any remaining balance will be forfeited.