AFFORDABLE CARE ACT#

The intent of the Affordable Care Act (ACA) is to insure that large companies offer their full time employees coverage in a health care plan that meets the Minimum Essential Coverage (MEC) and is affordable. Employees must be offered minimum self-only coverage in the plan, but it is not a requirement that the employee enrolls in the coverage.

Terminology#

Administrative period#

An optional period of no longer than 90 days, beginning immediately following the end of a measurement period, and ending immediately before the start of an associated stability period. An administrative period also includes the period between a new employee’s start date and the beginning of the initial measurement period, if the initial measurement period does not begin on the employee’s start date.

Monthly equivalency#

130 hours of service in a calendar month is treated as the monthly equivalency of at least 30 hours of service per week. The 130 hours of service applies to both the lookback measurement method and the monthly measurement method.

Full time employee#

The term means, with respect to a calendar month, an employee who is employed and averages at least 30 hours of service per week.

Part-time employee#

The term means a new employee who the employer reasonably expects to be employed on average less than 30 hours of service per week, or less than 130 hours per month during the initial measurement period.

Seasonal employee#

An employee who is hired into a position for which the customary annual employment is six months or less.

Seasonal worker#

An employee who performs work on a seasonal basis such as retail workers employed exclusively during holiday seasons.

Ongoing employee#

An employee who has been employed for at least one complete measurement period.

Variable Hour Employee#

The term applies to an employee where it cannot be reasonably determined that the employee will be employed on average at least 30 hours per week, during the initial measurement period.

Initial Measurement Period#

The term means a period defined by the employer of at least three consecutive months but not more than 12 consecutive months used as a part of the lookback measurement method. This definition is used to describe the first lookback measurement period for a new employee or an employee returning after a break in service.

Standard Measurement Period#

The term means a period defined by the employer of at least three consecutive months but not more than 12 consecutive months used as a part of the lookback measurement method.

Weekly Measurement Period#

Under the Weekly Measurement rule, full-time employee status is determined based on hours of service over four weekly periods, and for certain months over five weekly periods.
For a month with four weekly periods the employee must have at least 120 hours of service.
For a month with five weekly periods, the employee must have at least 150 hours of service. The following method is used to determine the hours of service for the weekly period:

• Beginning on the first day of the week that includes the first day of the calendar month, provided that the period over which hours are calculated does not include the week which in which the last day of the month falls, unless the week ends with the last day of the month in which case it is included.
• Users can define a specific day for the start of the week, in the 'Start Day of Week' field on IBACA.

Limited Non-Assessment Period#

This refers to a period of time during which an employer will not be subject to an assessable payment. Applies to employees in the following circumstances:

a) A three full calendar month period beginning with the first full calendar month, in which an employee is first eligible for an offer of coverage, under the monthly measurement method.

b) The initial three full calendar months of employment for an employee reasonably expected to be a full time employee at the start date, under the lookback measurement method

c) During the Initial Measurement Period, for a new variable hourly, seasonal, or part-time employee, determined to be employed on average at least 30 hours of service a week, under the look back measurement method.

d) A calendar month in which an employee’s start date occurs on a day other than the first day of the month.

Stability Period#

A period selected by the employer that immediately follows, and is associated with, a standard measurement period or an initial measurement period, and is used by the employer as a part of the lookback measurement method. The stability period cannot be less than six months or greater than 12 months.

Hour of Service#

The term means each hour for which an employee is paid, or is entitled to be paid, for performance of duties, or for a period of time during which no duties were performed due to vacation, holiday, illness, disability, layoff, jury duty, military duty, or a leave of absence. Users must refer to the following ESDC web site for government information and publication.

Required Set Up#

Step 1 - Define Benefit Plan Types IBPT #

The ACA Eligible toggle should be set to ON for the medical plan types that will hold benefit plans, that will be used for ACA minimum coverage purposes.

NOTE: The ACA Self-Insured toggle is no longer used. That determination is made on individual plans.

Step 2 - Define Benefit Plan/Coverages IBPN #

Medical plans typically contain multiple coverages. Self-insured plans are defined on IBPN, 'Plan Details' tab by setting the 'ACA Self Insured' toggle to ON.

If the medical plan type is defined as self-insured, then all benefit plans that are associated with the medical plan type must have the 'ACA Self Insured' toggle set to ON in order to include all dependent sons and daughters in the ACA reporting.

On the 'Coverage Details' tab, further information about the affordability and level of the coverage, for ACA purposes, is required.

Only the basic self-only coverage should be defined as the minimum value coverage. If more than one coverage is selected, the ACA process will only use the coverage with the lowest cost premium. If there are multiple medical plans offered to employees, only one should be selected.
NOTE: Coverage can be defined as a waived coverage. Set the ACA MONTHLY EE PREM to "-1" for the coverage to be reported as not enrolled. Waived coverage is the coverage that an employee selects in Open Enrollment when an offer is declined. This will not be reported as enrolled for ACA reporting. For this to show in RBEN add benefit components with zero amounts(i.e. B840 and/or B1040)

ACA Min. Value Self	As the system has no way to determine if the plan meets Minimum Essential Coverage, as defined by the IRS Rules, users would only set this toggle to ON if the plan is self-only.
ACA Monthly EE Prem	This is the cost to the employee for this coverage. It may be the employee deduction rate from the Rates tab, or another value. Note: this value must be defined as a monthly rate.
ACA Coverage	This is used for ACA reporting on the 1095C form. The options listed are for the type of coverage selected. The value will be shown as a code in Line 14 on the 1095C form and in VBACAE. Refer to the list of Line 14 codes.
ACA UserCalc	This option allows a UserCalc to compute the ACA Monthly Employee Premium, rather than populate it from the ACA Monthly EE Prem field. This provides users with the flexibility to calculate pro-rations or other computations, as needed. The value from the UserCalc will be displayed in VBACAE, IBACAE and in the UBACA spreadsheet.

The UserCalc Product is BE and is a Function type. It will return a number value which will be used by UBACA as the ACA Monthly EE Premium rate (this will override any rate entered into the ACA Monthly EE Prem in IBPN).

UserCalcs executed from within UBACA have access to these tables:

Form	Table
IBPT	BPT
IBPN	BPN, BCG, BCGD, BCGC and BCGR
IBEN	BEN and BEND
IEID	EID
IEEI	EEM
IEAS	EAS and EASD
IEST	EST
IDUN	DUN (not details)
IDGR	DGR (not details)

NOTE: Coverage can be defined as a waived coverage. Set the ACA MONTHLY EE PREM to "-1" for the coverage to be reported as not enrolled. Waived coverage is the coverage that an employee selects in Open Enrollment when an offer is declined. This will not be reported as enrolled for ACA reporting.

Step 3 - Define Benefit Schedules IBSC #

The IRS rules state that minimum affordable coverage must be offered to all full time employees, defined as employees who work a minimum of 130 hours during the month. The medical plan selected must be setup on IBSC so it is offered to all full time employees, and any part time employees who could exceed the 130 hours minimum.

ACA Rules state that coverage must be 'offered' to all full time employees although they do not have to actually be enrolled in that minimum coverage, or any coverage. Personality defines whether a plan/coverage is offered from IBSC in the list of benefit plans available for enrollment.

Step 4 - Define ACA Categories IBACA #

The IRS rules defines some Employee Categories that permit employers to apply different measurement and stability periods, provided that employees within each category are treated consistently.

The measurement and stability periods can differ, either in length or in their start and end dates, for different categories of employees defined in the regulations. The categories defined in the regulations are:

a. Salaried employees and hourly employees

b. Employees whose primary place(s) of employment are in different states

c. Collectively bargained employees and non-collectively bargained employees

d. Each group of collectively bargained employees covered by a separate collective bargaining arrangement.

The Employee Categories are defined on IBACA, together with options for managing each category, including an hours rule, a payroll rule, a wage rule and the measurement/look-back option, an element for hours and an element for wages.

IBACA Form Fields

ACA Category	Mandatory code to identify your ACA Category
Description	Optional. Description of the ACA Category
Entity	Optional. Required only if there are multiple entities and different rules for them.
State, Country	Optional. required only if organizations are employing in multiple states and have different rules for them.
Unit	Optional. Required only organizations have different rules by unit and want to report in this manner (not required).
ACA Hours Rule	Look-Back: When this value is chosen, the values on the IBACA 'Look Back' section must be completed. Monthly Measurement: Computes the hours an employee works by only looking at the month entered on UBACA. Weekly Measurement: Calculates the hours worked by week, within a month, to determine fulltime status. The number of weeks in the measurement month may be 4 or 5, depending on the month selected in UBACA. Four weeks will use 120 hours for the minimum hours and five weeks will use 150.
Start Day of Week	For use only with the Weekly Measurement method. Defines a specific day as the start of the week.
Hours Element *	Defines the Element that contains all pay components that represent paid time taken.
ACA Wage Rule	Federal Poverty Level: Uses the monthly federal poverty level, defined as the FPL user variable on (IMVR). Rate of Pay: Determines the wage rate, as defined in the ACA Payroll field, below. Form W2 Wages: Uses the month-to-date values from IPVT for the month defined on UBACA, and the Element identified as the wages element.
Wages Element	This element should represent W2 wages as reported in Box 1 on the W2 form. This represents federal taxable earnings and federal supplemental taxable wages.
ACA Payroll	Hourly: The monthly wage is determined as follows, defined by IRS rules: 130 x the lowest hourly Pay Line Detail (IPPH) wage rate, during the calendar month defined on UBACA, for transactions on the pay component identified in the Hours Element. *Salary: The monthly wage is determined by the wage rate on IEAS, on the first day of the month defined on UBACA.

If using the Look-back method as your ACA Hours Rule setting, the following fields should be defined:

Lookback Months	Must contain a number of months from 3 to 12.
Measure Period Start	Optional field. Defines the day in a month that the measurement period will start.
Admin Period	Optional field. Cannot be more than 90 days.
Stability Period	Optional field. Defines the length of the stability period and must be between 6 and 12 months.
Service Break Rule	This is for future development.
Leave Element	This is for future development.

*Hours per Day and Week

On IBACA, if the ACA Wage Rule is defined as 'Rate of Pay' and the ACA Payroll is defined as Salary, then there must be hours per week/day available for the calculation of a monthly wage to occur. Hours per Day and Week must be entered on at least one of the following forms:

IDWR – Work Rules

IDGR – Groups

DPS – Positions

IDJB – Jobs

IEAS - Assignments

This is also the order of screens that the function looks at to determine if hours exist.

Step 5 - Define User Variables IMVR #

On IBACA, if the ACA Wage Rule is defined as ‘Federal Poverty Level’ (FPL), an FPL user variable must be set up.
NOTE: It is up to each organization to maintain this value each year as the Federal Poverty Level value changes and is not hard coded in Personality. This is a date sensitive record and reflects the annual FPL rate.

The 'Affordability' user variable is created automatically by the UBACA software, if it does not already exist. Organizations MUST also update this value annually.

Step 6 – Define Groups IDGR#

The ACA Category is defined at the group level. This is the recommended level to apply it.

Step 7 – Maintain Assignments IEAS#

Certain settings for ACA reporting can be overridden at the Employee level, as defined on the IEAS form:

ACA Category	Optional field. Users can define an ACA Category (IBACA) which will override any value on the Employee’s group level.
ACA Excluded	Optional field. Users can define a value which will override the Line 14 value for a specific employee. No offer: Results in a Line 14 code of 1H and no calculations will be performed.

Step 8 – Self-Insured Provisions and Dependents#

If a plan is self-insured, organizations must provide and store information related to the employee's dependents. Dependents are defined on IECT when the 'Dependent' column is set to YES. Beneficiary and Emergency Contacts are also defined on this form, if applicable.

If a dependent is covered by an enrolled health plan, it will be shown on the Benefit Recipients data, either through the IBRP (by Plan) or through IBRA (by dependent) forms. These two forms hold the same data, but the information is presented differently.

Note: The Benefit percentage must be defined for UBACA to pick up these records and note that the dependent is covered.

Step 9 – Defining Values for the 1095C/1094C Forms and File#

The Annual ACA patch will create an IDIF definition for the current reporting year, which is provided as a template for organizations to fill in the constant values that are needed to successfully complete the 1095C forms and the 1094C form/file. IMPORTANT NOTE: It is recommended that each organization make a copy of their IDIF from the current year Form Code, to preserve these values on this release and any subsequent patch updates.

This IDIF definition contains 47 values that may need to be modified to values that are for your organization. These values are used in the production of the 1095C form (Employee Copy) and the 1094C form and file that must be submitted to the IRS.

The Rec # and Field # fields are inconsequential in this definition. What is important is the name of the field that the system is looking for and the constant value that is provided.

Variable Name (from IRS)	Usage	1094C Form/File Location
ALEMemberSetUp	To identify how ALE Members (Employers) are set up in Personality. IDEN - ALE Member set up as Entity in IDEN. This is the default. IDDP - ALE Member set up as Department in IDDP. IDLN - ALE Member set up as Location in IDLN IDGR - ALE Member set up as Group in IDGR	Applicable Large Employer Member (Employer) Information
TCC	Transmitter Control Code. Enter the TCC the IRS assigned your organization when your application for eFile was approved.	1094C file only
TestScenariold	The TestScenarioId is only applicable to transmissions submitted to AATS and identifies which test scenario the Form 1094-C represents.	Used by High Line for Software ID validation.
TINRequestTypeCd	A code to identify the TIN Request Type of the ALE Member. Values allowed are * INDIVIDUAL_TIN * BUSINESS_TIN * UNKNOWN	1094C file only
EmployerEIN	The Employer Identification Number assigned by the IRS to the large employer that is filing the 1094C form and associated 1095C forms.	1094C Box 2
ALEName	Employer Name override	1094C and 1095C
ALEAddress1	Employer Address 1 Override
ALEAddress2	Employer Address 2 Override
ALECityTown	Employer City/Town Override
ALEState	Employer State Override
ALECountry	Employer Country Override
ALEZip	Employer Zip Code Override
ContactPersonFirstNm	The first name of the contact person that the IRS should contact if they have questions about the submission.	1094C Box 7
ContactPersonMiddleNm	The middle name of the contact person that the IRS should contact if they have questions about the submission.	1094C Box 7
ContactPersonLastNm	The last name of the contact person that the IRS should contact if they have questions about the submission.	1094C Box 7
ContactSuffixNm	The suffix of the contact person that the IRS should contact if they have questions about the submission.	1094C Box 7
ContactPhoneNum	The phone number of the contact person that the IRS should contact if they have questions about the submission.	1095C: This phone # will appear on the top left of the 1095C form and on the 1094C form, Box 8.

**The following fields pertain to the Designated Government Entity (DGE) employer identification. This whole DGE section is optional.

DGEBusinessNameLine1Txt	This is the Designated Government Entity business name. Maximum length is 75 characters.	1094C Box 9
DGEBusinessNameLine2Txt	Optional. Maximum length is 75 characters.	1094C Box 9
DGETINRequestTypeCd	A code to identify the TIN Request Type of the Designated Government Entity. Values allowed are * INDIVIDUAL_TIN * BUSINESS_TIN * UNKNOWN	1094C file only
DGEEmployerEIN	Employer Identification Number assigned by the IRS to the Designated Government Entity.	1094C Box 10
DGEAddressLine1Txt	The first line containing the street address of the Designated Government Entity. Maximum length is 35 characters	1094C Box 11
DGEAddressLine2Txt	The second line containing the street address of the Designated Government Entity. Maximum length is 35 characters	1094C Box 11
DGECityNm	The City of the street address of the Designated Government Entity. Maximum length is 22 characters.	1094C Box 12
DGEUSStateCd	Two-character code for the State of the street address of the Designated Government Entity.	1094C Box 13
DGEUSZIPCd	Five-digit ZIP code of the street address of the Designated Government Entity.	1094C Box 14
DGEUSZIPExtensionCd	Four-digit ZIP Extension of the street address of the Designated Government Entity.	1094C Box 14
DGEPersonFirstNm	The name of the contact person for the Designated Government Entity that IRS should contact if they have questions about the submission.	1094C Box 15
DGEPersonMiddleNm	The name of the contact person for the Designated Government Entity that IRS should contact if they have questions about the submission.	1094C Box 15
DGEPersonLastNm	The name of the contact person for the Designated Government Entity that IRS should contact if they have questions about the submission.	1094C Box 15
DGESuffixNm	The name of the contact person for the Designated Government Entity that IRS should contact if they have questions about the submission.	1094C Box 15
DGEContactPhoneNum	The phone number of the contact person for the Designated Government Entity that IRS should contact if they have questions about the submission.	1094C Box 16
AuthoritativeTransmittalInd	Indicates if this is the authoritative transmittal for the ALE Member. Include 'AuthoritativeTransmittalInd' with the enumeration "0" for false and "1" for true.	1094C Box 19
TotalNumOf1095Filed	If you are overriding the number of records found on VBACAE, such as the number of employment records, enter the count of 1095 forms. Otherwise, the system will derive this value by counting the records in VBACAE (unique employees).	1094C Box 20
AggregatedGroupMemberCd	Indicates if the employer is a member of an Aggregated ALE Group or not. Select: 1 for YES 2 for NO	1094C Box 21
QualifyingOfferMethodInd	Indicates if the employer is eligible to use, and are using, the Qualifying Offer Method. Select: 1 for True 0 for False	1094C Box 22A
QlfyOfferMethodTrnstReliefInd	Indicates if the employer is eligible to use, and are using, the Qualifying Offer Method Transition Relief. Select: 1 for True 0 for False	1094C Box 22B
NinetyEightPctOfferMethodInd	Indicates if the employer is eligible to use, and are using, the 98% Offer Method. Select: 1 for True 0 for False	1094C Box 22A
JuratSignaturePIN	A PIN that provides attestation (signature) for the filer to the information contained in the 1094C Form and the associated 1095C Forms.	1094C file only
PlanStartMonth	Fill in this value if your organization would like to have Plan Start Month printed on your 1095C forms. This is an optional field for TY 2016 filing.	1095C Plan Start Month
PriorYearDataInd	Select: 0 for current filing year 1 for prior filing year	1094C file only
Receipt ID	The Receipt ID of the transmission the replacement transmissions are submitted for. This is obtained from the IRS website after the file is submitted, and is used for submitting all subsequent corrections.	1094C file only
TransForeignEntityInd	1 identifies the transmitter as a foreign Entity. Do not include XML tags if the transmitter is not a foreign Entity.	1094C file only
VendorCd	Identifies if the software was developed by a vendor (V) or in-house (I).	V
VendorPersonFirstNm	Vendor Contact Person First Name	Brian
VendorPersonMiddleNm	Vendor Contact Person Middle Name
VendorPersonLastNm	Vendor Contact Person Last Name	Diamond
VendorSuffixNm	Vendor Contact Suffix
VendorContactPhoneNum	Vendor Contact Phone Number	9059408777
SoftwareID	The software ID assigned to the software when the software was registered and approved by the IRS	2019 Software ID 19A0009607 is included in the ACA patch.

Authoritative Transmittal for ALE Members Filing Multiple Forms 1094C
A 1094C form must be filed when an ALE Member files one or more 1095C forms. An ALE Member can choose to file multiple 1094C forms, each accompanied by 1095C forms for a portion of its employees, provided that a 1095C form is filed for each employee for whom the ALE Member is required to file.

If an ALE Member files more than one 1094C form, one (and only one) 1094C form filed by the ALE Member must be identified on Line 19, Part I as the Authoritative Transmittal, and, on the Authoritative Transmittal, the ALE Member must report certain aggregate data for all full-time employees and all employees, as applicable.

IDIF set up and RB1094C process for multiple entity 1094C filing

1. Set the IDIF Authoritative Transmittal to '0' and run RB1094C for all entities. Record the Line 18 (total number of 1095C forms with this transmittal) values for each entity.
2. Add all Line 18 values, for all the entities, to get the total number of 1095C forms.
3. Make a copy or modify your IDIF for the Entity that the 1094C Authoritative transmittal will be submitted for all entities on Line 19 of the 1094C forms.
4. Set Authoritative Transmittal to '1' and the TotalNumOf1095Filed with the total number of 1095Cs for all entities.
5. Ensure that the entity with Authoritative Transmittal defined as '1' has the proper employer name, address and EIN, and re-run RB1094C for this entity.

NOTE: The Entity reporting Line 19 will report the total number of 1095Cs on Line 20 and will have Part I, Part II and Part III filled out. It will also have the AuthoritativeTransmittalInd tag on the xml file. Any other Entities will only have Part I completed on the 1094C form and will not have the tag on the xml file.

Employer Information Sources from Personality There are three sources of Applicable Large Employer Member (Employer) Information that can be set up on IDIF using the ALEMemberSetUp field by entering the Constant Value field with:

• IDEN - ALE Member set up as Entity on IDEN. This is the default.
• IDDP - ALE Member set up as Department on IDDP
• IDLN - ALE Member set up as Location on IDLN
• IDGR - ALE Member set up as Group on IDGR

NOTE: The default set up is IDEN. If IDDP is used, filter by Department when RB1095C is run. If IDLN is used, filter by Location when RB1095C is run. If IDGR is used, filter by Group when RB1095C is run.

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ACA EXECUTION#

UBACA – Affordable Care Act Report#

This report is run on a monthly basis and will report on employee data for the year/month as defined in the Year (YYYY) and Month (MM) fields.

If IBACA has ACA categories that are using the ACA Hours Rule 'Look-Back' rule, then the time accumulated from the months that have been defined as the Look Back period will be used to create the average hours, for the hours worked, for the month defined.

UBACA will only process employees whose assignment employment status is Active, Pending, Leave, Unpaid Leave, Retired, Cobra and Terminated (up to the month of termination).

This report will generate a Microsoft Excel spreadsheet. This allows users to sort, manipulate and/or analyze data in the records.

Exception messages can be viewed in the Excel spreadsheet and Exception messages can always be viewed in DMEX, VMEXF, VMEX and RMEX.

UBACA Report Criteria

Field	Description
Entity	Mandatory. Run UBACA for only one Entity at a time.
Year	Enter the year to report on
Month	Enter the month to report on
Use Eligibilty Date	Default (empty) is No. If this field is set to Yes, the Eligibility Start/End dates will be used to determine when an employee is covered by a plan, rather than the Effective and Expiry dates. Although this may suit an organization's set up better, note that there is no constraint or guarantee that eligibility dates are contiguous, without gaps or without overlap. If this parameter is defined, then only those records with the eligibility dates filled in will be reviewed.
Exception Level	Defines the level of detail to be printed.

There are three tabs at the bottom of the spreadsheet:

• The PARAMETERS tab will show the report parameters that were selected in UBACA
• The RUN LOG tab will show the execution trace and other diagnostic messages
• The REPORT tab will show the data in the report

Some key fields are:

Full Time	The determination if an employee is full time or part time is made based on the Hours worked in the Hours field. If the hours are less than 130, then for ACA reporting purposes, the employee is Part Time. Example: there will be a No in this field.
Hours	If the IBACA ACA Hours Rule is 'Monthly Measurement' these are the hours worked in the month being reported. If the rule is 'Look-Back', then this number will represent the average hours worked during the look-back period, defined in the 'Lookback Months' field.
Wage Rate	This derived from a source based on the ACA Wage Rule.
Enrolled Plan	This is the medical benefit plan the employee is actually enrolled in on IBEN
Enrolled Coverage	This is the medical benefit plan coverage the employee is enrolled in on IBEN
Line 14 Code	This is the Line 14 code relating to the employee for the reported month
Line 16 Code	This is the Line 16 code relating to the employee for the reported month
Offered Plan	This is the medical plan that has the lowest cost for the employee. This may not be the same as the enrolled plan, as this information is coming from IBSC.
Offered Coverage	This is the medical plan's self-only coverage that has the lowest cost for the employee. This may not be the same as the enrolled plan, as this information is coming from IBSC.
Coverage Rate	This is derived from the 'ACA Monthly EE Prem' field on IBPN, 'Coverage' tab, with the ACA Min. Value Self toggle. This will be the same for all employees enrolled in the same Plan on IBSC.
Affordability	This is derived by the UBACA calculations. The Yes/No option in this column is determined by the calculation done by UBACA.  If 9.86% of the Wage Rate is less than the Cost, then the plan is not affordable and a No is populated in this field.

If a plan is self-insured and the employee has dependent children, this information will be shown on the report. Up to 4 dependents can be shown on the report. All dependents are stored in the database and will be reported on the 1095C report, and are shown on the VBACAE form.

VBACAE – View ACA Monthly Data by EE #

The VBACAE is an employee form where the results of UBACA computations can be viewed. The UBACA report and 1094C/1095C reports get their data by reading this information.

IBACAE - Define ACA Monthly data by EE#

Data can be manually corrected in IBACAE, except for the Final toggle. The 1094C and 1095C reports read this data and does no further computations. Consequently, what you see in the VBACAE/IBACAE forms represent what will be output.

IMPORTANT NOTE: There are no edits on this form beyond the basics required for database integrity. Users can enter any values they wish, including linking employee contacts who may not be associated to the ACA-identified health plan.

• The Year and Month fields are derived from the Year (YYYY) and Month (MM) fields on UBACA.

• The ACA Category is read from the employee’s Group form or from the Assignment form, if an override exists.

• The 'Enrolled in Plan/Coverage' field will show the current enrollment of the employee in the medical plan and coverage, if any.
  
  

The Line 14 box may contain one of the following codes, and will be printed on the 1095C accordingly:

• Logic enhanced in switching 1E to 1A when ACA Wage Rule = 'PL'. Only switch to 1E if Offered Coverage is also 1E and it's ACA Monthly EE Prem <= 9.5% of federal poverty line.

Code	Description
1A	Qualifying Offer: Minimum essential coverage providing minimum value offered to a full-time employee with employee contribution for self-only coverage equal to or less than 9.5% mainland single federal poverty line and at least minimum essential coverage offered to spouse and dependent(s).
1B	Minimum essential coverage providing minimum value offered to employee only.
1C	Minimum essential coverage providing minimum value offered to employee and at least minimum essential coverage offered to dependent(s), (not spouse).
1D	Minimum essential coverage providing minimum value offered to employee and at least minimum essential coverage offered to spouse, (not dependent(s)).
1E	Minimum essential coverage providing minimum value offered to employee and at least minimum essential coverage offered to dependent(s) and spouse.
1F	Minimum essential coverage NOT providing minimum value offered to employee, or employee and spouse or dependent(s), or employee, spouse and dependents. NOTE: Code 1F is not currently set by the UBACA process and must be manually set on IBACAE.
1G	Offer of coverage to employee who was not a full-time employee for any month of the calendar year, and who enrolled in self-insured coverage for one or more months of the calendar year.
1H	No offer of coverage (employee not offered any health coverage or employee offered coverage that is not minimum essential coverage). This is set on IEAS. NOTE: An employee who is Terminated and offered a COBRA/Retiree continuation coverage would have Line 14 = 1H and Line 16 = 2B during the fist month of retirement (transition from Active to Retiree). During the month that the employee is a Retireee for the whole month, Line 14 = 1H and Line 16 = 2A.
1J	Minimum essential coverage providing minimum value offered to employee and at least minimum essential coverage conditionally offered to spouse, minimum essential coverage not offered to dependent(s).
1K	Minimum essential coverage providing minimum value offered to employee, at least minimum essential coverage offered to dependent(s), and at least minimum essential coverage conditionally offered to spouse.

The Line 16 box may contain one of the following codes, and will be printed in the 1095C accordingly:

2A	Employee was not employed during the month
2B	Employee is not a full-time employee
2C	Employee is enrolled in coverage offered
2D	Employee in a section 4980H(b) Limited Non-Assessment Period. Enter code 2D for any month during which an employee is in a Limited Non-Assessment Period for section 4980H(b).
2E	Multi-employer interim rule relief. Enter code 2E for any month that the multi-employer interim guidance applies for the employee.
2F	Section 4980H affordability Form W-2 safe harbor
2G	Section 4980H affordability federal poverty line safe harbor
2H	Section 4980H affordability rate of pay safe harbor

2D and 2E, above, are not currently set by the UBACA process and must be manually entered in IBACAE.

IMPORTANT NOTE: Line 16 will be blank for any month that the ALE member did not offer minimum essential coverage to at least 95% of its full-time employees and their dependents.

The 'ACA Period' is populated by UBACA only when a look-back measurement period is selected for the employee. The options are:

ACA Period	Description
Administration Period	For ongoing employees, this is the period following the end of the measurement period and ending immediately before the stability period.
Initial Period	For new hires, starting on the fourth full calendar month to the end of the Lookback month.
Non Assessment Period	For new hires, their first partial month and their first three full calendar months.
Stability Period	A full time employee is put into a stability period for the duration of one year, based upon the date that is stamped in IEEI. To remove an employee from a stability period, remove this date. When an employee is in a stability period, no computations are made to hours worked or wages, as the previous month’s values will be used. NOTE: After completing the previous year for Look Back category, this date will be used going forward.
Standard Measurement Period	A period defined by the employer of at least three consecutive months, but not more than 12 consecutive months, used as a part of the Look Back measurement period.

• 'Offered Plan/Coverage' will show the medical plan/coverage that has the lowest cost, offered to the employee.

• 'Coverage Rate' is the ACA Monthly EE Premium of the plan/coverage that has the lowest cost, offered to the employee.

• 'Wage Rate' is the rate of pay considered by ACA, depending on the ACA Wage Rule.

• 'Hours' is the calculated ACA worked hours, based on the ACA Hours Rule.

• 'FT' will be toggled ON if UBACA determines that the employee is Full Time (has worked an average of more than 130 hours per month).

The lower section of this form will show any dependents if:

• The plan is designated as ACA Self Insured in IBPN, and
• There are dependents defined on IECT with the 'Dependent' field set to YES, and
• The dependents are associated with the Medical plan on IBRA at a coverage rate greater than 0 (or null).

NOTE: When UBACA is run for the months that are in an employee’s Stability Period, no data is recalculated by UBACA. Current data for the month will be copied from the data generated when the stability period was first initiated.

NOTE: If the option 'Generate for 1095C' is set to YES, then all employees in the selected Entity will be included in the report, filters are ignored, and the results are saved to the database for reporting at year-end.

If a user has previously processed a month with this option set to YES, then subsequent runs with the flag set to NO will just report the data again and will not re-compute the data.

The only intent of this toggle is to provide a performance aid if users need to run the UBACA report for multiple groups of people, but want to only show subsets of employees. Once there is a record for any employee with the “Final” toggle set to ON, UBACA does not go through the data for that month, but rather simply reports on the data that is in the database.

Users do not need to run UBACA with this toggle set to YES in order to produce 1095C/1094C output.

This report will generate a Microsoft Excel spreadsheet. This allows users to sort, manipulate and/or analyze data in the records.

Determining Line 14 Codes#

The UBACA program will determine the Line 14 and Line 16 Codes for use in the 1094C/1095C forms and file. The codes below reflect the order that they are determined.

SITUATION	Line 14 Code
IEAS Excluded flag is set to any value.	IH
Employee is terminated prior to the first of the month and they are not in an employment status of COBRA or Retiree	1H
Employee is hired this month and is therefore in the initial measurement period.	1H
Employee who is terminated and offered a COBRA/Retiree continuation coverage.	1H
Employee (not Cobra/Retiree) is enrolled in a IBPN coverage defined with 1E, but wage rule is set to Federal Poverty Line (FPL).	1A
Employee (not Cobra/Retiree) is enrolled in a IBPN coverage, is part time for all 12 months, and the policy is a Self-Insured policy	1G will be reported on the 1095C form but may have a different value on VBACAE. This value comes from IBPN coverage of highest offer (1A, 1B, 1C, 1D, 1E, 1G, 1H).
Employee (not Cobra/Retiree) is not offered any plan from IBSC.	1H
Employee (not Cobra/Retiree) is enrolled in a benefit plan.	This value comes from IBPN coverage of highest offer (1A, 1B, 1C, 1D, 1E, 1G, 1H).

Determining Line 16 Codes#

The UBACA program will determine the Line 14 and Line 16 Codes for use in the 1094C/1095C forms and file. The codes below reflect the order that they are determined

SITUATION	Line 16 Code
IEAS Excluded flag is set to any value.	Blank
For any month that the ALE member did not offer minimum essential coverage to at least 95% of its full-time employees and their dependents	Blank
Employee is terminated prior to the first day of the month and they are not in an employment status of COBRA or Retireee	2A
Employee is hired this month and is therefore in the initial measurement period.	2D
Employee who is terminated and offered a COBRA/Retiree continuation coverage.	2A, except for the transition month, which will be 2B
Employee is in a Non Assessment Period, Initial Period or Administration Period	2D
Employee is enrolled in any benefit plan (not only the minimum value self-only offer)	2C
Employee (not Cobra/Retiree) is part time and not enrolled in the minimum coverage offered (may be other coverage)	2B
Employee is offered coverage deemed affordable according to the Form W2 Wages rule, but is not enrolled in any plan	2F
Employee is offered coverage deemed affordable according to the Federal Poverty Line rule, but is not enrolled in any plan	2G
Employee is offered coverage deemed affordable according to the Rate of pay rule, but is not enrolled in any plan	2H
Employee is not enrolled in a plan, were terminated within the month and are not full time	2B
Employee was terminated prior to this month and is not enrolled in a plan	2A

IBACAE – Define ACA Monthly Data by EE#

This function will allow users to update the data generated by the UBACA function. This function is intended to allow for minor changes to the data generated for purposes of 'tweaking' individual data situations and is NOT intended to be a data entry form. As a result, only limited edits on the data are provided and users who modify the data generated by UBACA should do so at their own risk. Important Note: If the UBACA is run for the same employee, for the same month and year, it will wipe out all changes made manually on this form.

The 1095C and 1094C reports read from this data and do no further computation, so what you see in the VBACAE/IBACAE screens represent what will be output.

Important Note: There are no edits in this screen beyond the basics required for database integrity. You have the opportunity to enter any values that you wish, including the linking of employee contacts who may not be associated to the ACA-identified health plan.

IEEI – Employment Information#

A date will be added to ACA Stability Date field on IEEI only when the ACA Category in IBACA is using the Look Back method. The ACA Stability Date is derived by UBACA and inserted into this field. This is the start date of the Stability Period which will extend forward for the number of months defined in IBACA.

During this period UBACA will not recalculate hours worked or a wage rate to determine if the employee is FT or PT or whether the medical coverage is ‘Affordable.’ The employee’s ACA status is fixed as of this date and will extend to the end of the Stability Period when a new measurement period will determine the next stability date and ACA status. During a new employee’s UBACA processing, there will be no stability date entered until the last month of the Look Back period has been reached.

IEPW2/WEPW2/WMPW2 - Maintain Employee W-2 Consent#

Employees can receive an electronic W2 and 1095C form from Self Service. These forms allow employees to provide consent, or withdraw their consent, to printing their W2 and 1095C forms using Self Service. Employers can manage the consent for employees to receive electronic W2 and 1095C forms.

RB1095C/RB1095SM –Producing the 1095C Form#

These functions and reports will create the 1095C form, except for employees with electronic consent in the following releases of Personality:

• NextGen - 5.04 + 5.05

There are two different functions to produce a 1095C form.

• RB1095C will produce the form on blank 8½“ X11“ paper, and may be printed double sided (duplex)
• RB1095SM will produce the form single sided on an 11” X 14” self-mailer form MW1095C (from RR Donnelley) or equivalent.

The 1095C form for employees is produced on blank paper using the RB1095C/RB1095SM programs. These programs read the data from VBACAE and produces one page per employee (additional pages as required for overflow of dependents).

RB1095C/RB1095SM Report Parameters

Parameter	Description
Entity	Defines the Entity the 1095C forms are produced for.
Year	Defines the year the 1095C forms are produced for
As of Date	This parameter is used to retrieve the current Assignment and Group information for an employee, as of the date defined.
Final (check toggle)	Is set to Y, the 'Final' toggle in VBACAE/IBACAE will be checked. The default value is N.
Corrected	If this value is set to “Yes”, the 1095C form will be printed with a check mark in the CORRECTED field.
Interface Code	The name of the IDIF definition that is used to create the 1094C form/file. The HL supplied IDIF is HL$ACA-1094C. Details for this interface code can be found in IDIF – Defining values for the 1095C/1094C Forms and File section.
Hide SSN	When set to “Y”, Social Security Numbers are obfuscated with leading “X”’s
Blank Out L16(14=1A)	When set to "Y", the Line 16 value will be blanked out when Line 14 is set to 1A. The default value is "N".
Override Line 16	When set to “Y”, Line 16 will still be populated even if the Minimum Essential Coverage Offer (MEC) is less than 95% of the full-time employees in the system and the MEC indicator ‘No’ box is toggled on the 1094c form Part III.
Skip Part Time EE	When set to “Y”, 1095C will not include employees who were not full-time employees in any month of the year and were not enrolled in an ACA benefit plan.
Sort By	How the 1095C forms should be sorted. The available options are: Pay Destination + Department Code + Last Name Pay Destination + Last Name Auth Area + Last Name Last Name. This is the default if none of the above options are chosen.

RB1095C/RB1095SM Report Filters

• These filters can be used to produce a subset of 1095C forms for specific employees or groups of employees.

NOTE:

• • If ALEMemberSetUp is set up with IDLN, then the 'Location' filter should be defined.
  • If ALEMemberSetUp is set up with IDDP, then the 'Department' filter should be defined.
  • If ALEMemberSetUp is set up with IDGR, then the 'Group' filter should be defined

• The RB1095C process will produce a PDF file that contains a 1095C form for each employee. This can be printed on blank paper, with the instructions printed on the back (if printing duplex).

• If applicable, a continuation page for Part III Covered Individuals will be printed following the 1095C form.

RB1094C – Producing the 1094C Form and File#

The RB1094C program reports on the data found on VBACAE and produces the Employer’s 1094C form, as well as the 1094C file for submission to the IRS.

There are two methods of transmission of the 1094C file:

• A2A: Application to Application
• UI: User Interface

For TY 2017 filing, only UI is supported.

NOTE:

• Each organization must apply for, and receive, a Transmitter Control Code (TCC) to eFile your ACA submission.
• Do not modify the .xml file manually as this will corrupt the checksum.
• Organizations must also submit a test form to the IRS for approval of the file format.

Important Note: It is recommended that you make a copy of the IDIF interface definition from the HL$ACA-1094C for your own site, so as to preserve your values on this and subsequent updates.

RB1094C Report Parameters

Parameter	Description
Entity	Defines the Entity the 1094C report/file is produced for
Year	Defines the reporting year for the 1094C report/file
As of Date	Start date for the reporting period. This will also determine date-sensitive information such as employee addresses.
Signature Date	This date populates the Signature Date on the file
Blank Out L16(14=1A)	When set to "Y", the Line 16 value will be blanked out when Line 14 is set to 1A. The default value is "N".
Skip Part Time EE	When set to “Y”, 1095C will not include employees who were not full-time employees in any month of the year and were not enrolled in an ACA benefit plan.
Correct Form	Defines which ACA form is being corrected. Options are: None, 1094C or 1095C
Transmission Type	Defines the tranmission type. Options are: C-Correction, O-Original, R-Replacement
Replacement Type	Defines the replacement type. Options are: Submission Replacement, Transmission Replacement
Test File Code	Defines the file code type. Options are: P-Production, T-AATS
Interface Code	Defines the name of the IDIF definition that is used to create the 1094C form/file. The HL supplied IDIF is HL$ACA1094C-yyyy. Details for this interface code can be found in the IDIF – Defining values for the 1095C/1094C Forms and File section.
Directory Name	Defines the directory where the 1094C file will be stored. The file name has a fixed name format.
Sort By	Defines how the employees will be sorted in the 1094C file
Exception Level	Defines the level of detail to be printed

RB 1094C Report Filters

• Use these filters to restrict the employees that are included in the 1094C report/file
  

• Any error messages will be output into the run log, which can be viewed on DMEX, VMEX, VMEXF or running RMEX.

• The 1094C File is named using the following naming convention:
  

1094C_Request_XXXXX_20151018T18103200Z.xml

Where XXXXX is your Transmitter Control Code (TCC) and 20151018T18103200 will be replaced with the date/time that the file is created.

• The manifest file is created using the naming convention and the full 1094C report is produced.

ACA Prior Tax Year Updates#

2019

• AIR TCCs for Transmitters and Issuers that are in Production status will remain in Production status. No additional testing is needed for Tax Year 2019.
• Software Developers need to update their ACA Application for TCC each year to obtain a new software identification number for the new tax year
• Software Developers who passed testing for any tax year ending after December 31, 2014 do not need to test for the current tax year. Software IDs are scheduled to move to Production one week from the date the software IDs are assigned.
  • When the 2019 software packages are added, Responsible Officials will need to re-sign the ACA Application for TCC.
  • AIR Transmissions (both live and test) will reject If the ACA Application for TCC is not signed and in Completed status.
  • Allow 48 hours before transmitting to Production after passing any required testing.

2018
To generate tax year 2018 returns in AATS until 10/24/2019 and Production until 12/31/2019, use:

• Manifest file from tax year 2018 schema package
• Form data file from tax year 2018 schema package
• PaymentYr value “2018”
• Software ID for 2018 (2018 software IDs start with 18XXXXXXXX)

2017
To generate tax year 2017 returns in AATS until 10/24/2019 and Production until 12/31/2019, use:

• Manifest file from the tax year 2017 schema package
• Form data file from the tax year 2017 schema package
• PaymentYr value: “2017”
• PriorYearDataInd value: “1”
• Software Id for 2017 (2017 software IDs start with 17XXXXXXXX)
• Use the Interface Format for 2017

2016
To generate tax year 2016 returns in AATS until 10/24/2019 and Production until 12/31/2019, use:

• Manifest file from tax year 2017 schema package for Production

To generate tax year 2016 returns in Production, use:

• Form data file from tax year 2016 schema package
• PaymentYr value “2016”
• PriorYearDataInd value “1”
• Software Id for 2016 (2016 software Ids start with 16XXXXXXXX)
• Use the Interface Format for 2016

Submitting Test Files#

The IRS requires that High Line, as part of the Software ID approval process, submit a series of test files with specific scenarios of data. These test files have been approved for 2019 and the 2019 Software ID is included in the ACA year end patch.

The IRS also requires employers to submit a test file, to confirm the transmission linkage. This file must contain no real employee data such as SSNs.

Only Clients who will be doing the ACA file transmission for the first time under their own TCC number are required to submit a test file for 2019.

High Line provides a transmission test file for clients using Personality ACA reporting for the first time in 2019.

XML file for Test Scenario 7

• Manifest_1094C_Request_BBJ4V_20180120T125609822Z.xml
• 1094C_Request_BBJ4V_20180120T125609822Z.xml

NOTE: Organizations need to replace our TCC (BBJ4V) with their own TCC for both:

• The .xml file name UniqueTransmissionId
• In the Manifest file DocumentSystemFileNm

DATA STRUCTURES#

P2K_BE_ACA_CATEGORIES#

Maintained by IBACA ACA Categories

P2K_BE_ACA_MONTHLY_DATA#

Created by UBACA / Viewed through VBACAE ACA Monthly Data

P2K_BE_ACA_DEPENDENTS#

Created by UBACA / Viewed through VBACAE ACA Dependents

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Notes #

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