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Affordable Care Act: Requirements, Tracking and Reporting

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Presentation on theme: "Affordable Care Act: Requirements, Tracking and Reporting"— Presentation transcript:

1 Affordable Care Act: Requirements, Tracking and Reporting
Don Lerew (Messiah College) Michelle Spencer (Dickinson College)

2 Thank you for your cooperation
General Announcements: Please turn off all cell phones/pagers If you must leave the session early, please do so as discreetly as possible Please avoid side conversations during the session Questions will be answered ….. Thank you for your cooperation

3 CPE Credits - We’ve gone electronic!
To receive CPE credits for this session (if eligible), complete the CPE Attendance Form on the PABUG Annual Conference website or via the PABUG conference app. For additional questions please contact Kim Fremont CPE - Coordinator

4 Institution Facts – DICKINSON COLLEGE
Dickinson is self-funded with approximately 840 full-time employees; over 700 of those are enrolled in medical insurance We are planning on running 1095’s from Banner (not outsourcing) Dickinson already tracks dependents on coverage in PDABCOV Must provide forms for those on COBRA coverage and retirees/terminated employees with an active VEBA Emeriti account

5 Institution Facts – MESSIAH COLLEGE
Messiah employees 625 full-time employees; 545 (87%) enrolled in medical insurance Messiah is NOT self-insured for medical insurance We are currently finalizing review to consider outsourcing 1095 process for 2016

6 Background, Regulations and Reporting
Affordable Care Act Background, Regulations and Reporting

7 ACA Regulations -- Background
ACA individual reporting requirements Started in 2014 “Individual play-or-pay” provision ACA employer requirements Started in 2015 For “applicable large employers” (ALE) “Employer play-or-pay” provision

8 ACA Regulations – Regulations
§4980H Applicable Large Employer (ALE) responsible to pay Employer Shared Responsibility (ESR) payment if employer fails to offer minimum essential health insurance coverage OR the coverage is either unaffordable or does not provide minimum essential value §4980H(c)(4)  Full-time Employee An employee who is employed, on average, at least 30 hours per week

9 ACA Regulations – Defining Periods
Measurement Period (M.P.) Period of 3-12 consecutive months over which employee service hours are averaged to determine if the employee is full time Initial Measurement Period (I.M.P.) For new variable-hour and seasonal employees Start date varies based on employee’s hire date Standard Measurement Period (S.M.P.) Employer-designated period that has fixed dates and applies to an entire group of employees

10 ACA Regulations – Defining Periods
Administrative Period (A.P.) Optional period that allows time to notify and enroll eligible employees for coverage Begins at the end of the M.P. and may last up to 90 calendar days Stability Period (S.P.) Immediately after A.P. or M.P. Employee is treated as full-time or non-full-time according to findings during measurement period Minimum six consecutive months; no shorter than M.P. for full-time employees; no longer than M.P. for non-full-time employees

11 ACA Regulations – Full-Time Employee
For calendar month, employee averages 30 hours of service per week or 130 hours of service per month Methods for Determining Full-Time Status Monthly Measurement Period Employee has at least 130 hours of service in a month Look-back Measurement Period Employee averages 30 hrs/wk or 130 hrs/mth over established look-back measurement period

12 ACA Regulations – Includable Hours
Each hour in which the employee is paid, or entitled to payment: For performance of duties For which no duties are performance Vacation, holiday, illness, incapacity (including disability), layoff, jury duty, military leave, leave of absence

13 ACA Regulations – Excludable Hours
Worker’s Compensation Volunteer employees for tax-exempt organization Students performing work study through federal work study program (or similar program) Unpaid Internships Non-US-Source Income Temp Agency Employees International Students (F, J, Q or M visas)

14 ACA Regulations – Hard-to-Classify
Break periods of 4+ consecutive weeks must be excluded or credited Adjuncts with 26-week breaks can be considered a new hire upon return Seasonal employees with annual employment six months or less are NOT considered full-time employees Adjuncts must be credited with a minimum of 2.25 hours/week of service for each hour of teaching or classroom time (safe harbor) On-call employees credited for any hour of service on-call for which payment is made or due by the employer

15 ACA Regulations – Challenges
Salaried employees in less-than-12-mth jobs Employees with reduced summer hours Graduate assistants if paid stipend Summer athletic camp workers Resident assistants Assistant coaches Others?

16 ACA Regulations – Employee Types
Ongoing Employee Has been employed by the employer for at least one complete standard measurement period New Employee Expected 30+ hours/week upon hire Variable Hour  cannot be determined to work 30 hrs/wk at start of initial measurement period Transition New  Ongoing Employee

17 ACA Regulations – Annual Reporting
IRC Code §6056 ALE must file returns to IRS for each employee who was a full-time employee during one or more months during the calendar year Can be paper or electronic Can be solely electronic only if employee consents

18 ACA Regulations – Annual Reporting
Employees will receive: 1095-C from employer 1095-B from insurance provider, unless self-insured for medical insurance IRS will receive 1094-C from employer 1094-B from insurance provider, unless self-insured for medical insurance COBRA reporting covered by insurance provider, unless self-insured for medical insurance

19 ACA Regulations – Due Dates
1095-C forms To each employee by January 31 1095-C forms & 1094-C transmittal To IRS by February 28 (electronically, March 31) 1095-B & 1094-B Dates follow due dates above when provided by insurance provider

20 Affordable Care Act Banner Processing

21 Banner Hours Tracking Setup Items
PTRBCAT Benefit Categories Is current structure sufficient? PTREARN Earnings Codes Are the hours/units flags accurate? GTVSDAX – include or exclude ECLS and EARN codes Run PHRAFCA process to look at hours by employee Payroll Are the includable hours of service processed such that all appropriate hours are tracked? Retroactive Pay How to handle late timesheets, etc.?

22 Banner Reporting Setup Items
PTRBDCA – Complete fields under the US ACA section for the medical benefit codes that provide minimum essential coverage GTVSDAX – holds the crosswalk codes for PTRBDCA medical benefit codes and plan codes on PDADEDN records PTROCMU – specified by ECLS; must populate if running the Mass Update Process (PDPOCMU) PDPOCMU – if using to auto populate PDAHIOC records PDAHIOC – individual employee ACA coverage records PDRHIOC – Audit Report Process; used in reviewing PDAHIOC records PDABENE – dependent names, DOB and SSNs PDABCOV – dependents on medical coverage

23 Benefits Mode – Indicating the Health Care Provider (PTRBDCA)

24 Benefits Mode – Crosswalk Validation (GTVSDAX)
At Dickinson, we have over 200 medical plan options. GTVSDAX is limited to only a 2 digit Sequence so we narrowed the list down to only those codes that are being utilized.

25 Benefits Mode - Mass Update Rule Form (PTROCMU)
Defaults are entered by Employee Class

26 Offer and Coverage Mass Update (PDPOCMU)
Automates the creation of Health Insurance Offer and Coverage records (PDAHIOC); Run in Rule Mode (by ECLS) or Benefit Mode (actually looks at PTRBDCA and effective dated changes) Requires new entries in GTVSDAX for Benefit Mode

27 Offer and Coverage Mass Update (PDPOCMU)

28 Health Insurance Offer and Coverage (PDAHIOC)

29 Offer and Coverage Audit Report (PDRHIOC)
Employees listed alphabetically by the employee class on PEAEMPL Includes an audit of ACA hours Offer and coverage records for each employee Messages identifying employees with no Offer and Coverage record, incorrect code combinations, employees not enrolled

30 Other ACA Items to Consider
Forms – Printing or providing electronic Forms – blank or pre-printed Forms – mailing with W-2 or separate Electronic files for ACA submission – Ellucian is testing Register with IRS to be authorized to transmit Affordable Care Act Information Returns (AIR) Program

31 Open to the Floor Questions Comments Discussion

32 Contact Information Don Lerew HRIS & Payroll Manager, Messiah College Michelle Spencer HRIS Administrator, Dickinson College

33 Please take time to complete our Conference and Session evaluations
Please take time to complete our Conference and Session evaluations. YOUR INPUT MATTERS!!!


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