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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.

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:
*IBPT form: BPT table
*IBPN form: BPN BCG BCGD BCGC BCGR tables
*IBEN form: BEN BEND tables
*IEID form: EID table
*IEEI form: EEM table
*IEAS form: EAS EASD tables
*IEST form: EST table
*IDUN form: DUN table (not details)
*IDGR form: DGR table (not details)

NOTE: New logic has been added so a coverage can be defined as a waived coverage. Waives 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.

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 'Dependant' 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
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
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	Robert
VendorPersonMiddleNm	Vendor Contact Person Middle Name
VendorPersonLastNm	Vendor Contact Person Last Name	Forbes
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	2017 Software ID 17A0005266 is included in the ACA patch.
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	Applicable Large Employer Member (Employer) Information

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ACA EXECUTION#

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: Note that 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.

RB1095x –Producing the 1095C Form#

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).

Report Parameters & Filters

Report Parameters
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".
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.

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.

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.

Report Parameters & Filters

Report Parameters
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
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".
Corrected 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

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.

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 #

Click to create a new notes page