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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 average of 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 130 hours per month during the initial measurement period.

Seasonal employee#

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

Seasonal worker#

The term means an employee who performs work on a seasonal basis such as retail workers employed exclusively during holiday seasons.

Ongoing employee#

This term means 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 selected 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 selected 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 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 select a specific day for the start of the week, in the Start Day of Week field in 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 hour, 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) To the 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 may not 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 leave of absence.The 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 is set on for the medical plan type that will hold benefit plans that will be used for ACA minimum coverage purposes.

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 will typically contain multiple coverages. If your plan is self-insured, then you would indicate that this particular plan is such on the IBPN screen plan details tab.

If the medical plan type is identified as a self-insured plan type, then all benefit plans that are associated with the medical plan type must have the ACA Self Insured toggle set 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 identified 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, you would only toggle on a self-only coverage if it meets that criterion.
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 that this value must represent 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. (See list of Line 14 codes on page 23).
ACA UserCalc	This option allows for a UserCalc to compute the ACA Monthly Employee Premium, rather than take it from the field above. This allows you to perform pro-rating or other computations as may be needed. The value from the UserCalc will be displayed in VBACAE and in the UBACA spreadsheet. The UserCalc Product is BE and is of a type Function. 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). Currently UserCalcs executed from within UBACA have access to these tables: *IBPT screen: BPT *IBPN screen: BPN BCG BCGD BCGC BCGR *IBEN screen: BEN BEND *IEID screen: EID *IEEI screen: EEM *IEAS screen: EAS EASD *IEST screen: EST *IDUN screen: DUN (not details) *IDGR screen: DGR (not details)

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 in the benefit schedule so that it is offered to all full time employees and must also include any part time employees who could exceed the 130 hours minimum.

The rule is 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. In Personality, being offered a plan/coverage requires that it shows (from the schedule) in the list of benefit plans available for enrollment.

Step 4 - Define ACA Categories IBACA #

The IRS rules defines some Employee Categories to which different measurement and stability periods may be applied.

The regulations permit an employer to use measurement periods and stability periods that differ either in length or in their starting and ending dates for different categories of employees specified in the regulations, provided that the employees within each category are treated consistently. The categories specified in the proposed regulations are:

a. Salaried employees and hourly employees,

b. Employees whose primary places 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.

Categories are defined in IBACA together with options for managing each category, which includes the hours rule, a payroll rule, a wage rule and the measurement/look-back option. Also defined is an element for hours and an element for wages.

ACA Category	Mandatory code that you will use to identify your ACA Category
Description	Optional, description of the ACA Category
Entity	Optional – only needed if you have multiple entities and different rules for them.
State, Country	Optional – only needed if you are employing in multiple states and have different rules for them.
Unit	Optional – only needed if you have different rules by unit and wish to identify them in this manner (not required)
ACA Hours Rule	Look-Back … If you choose Look-Back, you must fill in the fields below in the lookback section Monthly Measurement … This option will compute the hours an employee works by only looking at the month entered in the UBACA form. Weekly Measurement … This option will determine the hours worked by week within a month. 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, for determination of full time status.
Start Day of Week	Options are to select a specific day as the start of the week (for use only with the Weekly Measurement method).
Hours Element	The element selected here will contain all of the pay components that represent paid time taken.
ACA Wage Rule	Federal Poverty Level … This method uses the monthly federal poverty level entered into a user variable (IMVR) named FPL Rate of Pay … This method will determine the wage rate, as specified in the ACA Payroll field, below. Form W2 Wages … This method uses the month-to-date values from IPVT for the month selected in UBACA, for the element identified as the wages element.
Wages Element	This element should represent W2 wages as reported in Box-1 in form W-2. This represents federal taxable earnings and federal supplemental taxable wages.
ACA Payroll	Hourly … The monthly wage is determined as follows, as per IRS rule: 130 X the lowest hourly Pay Line (IPPH) wage rate during the calendar month identified in UBACA. Salary … The monthly wage is determined by looking at the IEAS wage rate on the first day of the month identified in UBACA.

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

Lookback Months	Must contain a number of months from 3 to 12.
Measure Period Start	Optional field. This date will define the day in a month that the measurement period will start
Admin Period	Optional field. May not 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.

Step 5 - Define User Variables IMVR #

If the IBACA option for the ACA Wage Rule ‘Federal Poverty Level’ is used, a user variable must be set up using FPL as the user variable code name. It is up to you to maintain this value each year as the Federal Poverty Level value changes. This is a date sensitive record and reflects the annual FPL rate.

Step 6 – Define Groups IDGR#

An ACA Category can be entered at the group level, and this is the recommended level to have it applied.

Step 7 – Maintain Assignments IEAS#

Certain settings for ACA processing may be overridden at employee levels, on the IEAS screen.

ACA Category	Optional field. You may enter an ACA Category (IBACA) here which will be an override to the one inherited from the employee’s group.
ACA Excluded	Optional field. You may enter a value here to override the line 14 value for this employee No offer … This will result in a Line 14 code of 1H and no calculations will be performed. Transition … This will result in a Line 14 code of 1I and no calculations will be performed.

Hours per Day and Week

If the ACA Wage Rule in IBACA has the Rate of Pay selected, and the ACA Payroll is Salary, then there must be hours per week/day available for the calculation of a monthly wage to take place. Hours per Day and Week must be entered into at least one of the following screens.

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 8 – Self-Insured Provisions and Dependents#

If your plan is self-insured, then you must also provide and store information related to dependents. An employee’s dependents are identified on the IECT Contacts screen and must be identified with a role of Dependent (other roles may also be used, if applicable).

If a dependent is covered by an enrolled health plan, this will be shown on the Benefit Recipients data. You can see this data through IBRP (by Plan) or through IBRA (by dependent) screens. These two screens present the same data, just viewed differently.

Note that the percentage must be filled in 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#

Starting with the 20151030 Release, an IDIF definition is provided as a template for you to fill in constant values that are needed to successfully complete the 1095C form and 1094C form/file.

A system-provided template definition is available in IDIF called HL$ACA-1094C.

It is recommended that you copy this template definition and a create copy (or copies) of your own, so that it is not overwritten in subsequent patch updates.

This IDIF definition contains 41 values that may need to be modified to values that are for your own organization. These values are used in the production of the 1095C form that is destined for the employee, and the 1094C form and file that must be submitted to the IRS.

The record number/field number are inconsequential in this definition. What is important is the name of the field that the system is looking for and the constant value you provide. Wiki : AFFORDABLE CARE ACT - Plugin insertion failed: Could not find plugin TableWiki : AFFORDABLE CARE ACT - Plugin insertion failed: Could not find plugin Table

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ACA EXECUTION#

IBACAE – Define ACA Monthly Data by EE#

There may be situations where the data generated by UBACA does not exactly match the needs for the employee. The Jan 11 release of the ACA software provides the means for you to edit the generated data.

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 lookback method. The ACA Stability Date is derived by UBACA and inserted into this field. It is the start date of the Stability Period which will extend forward for the number of months indicated 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 program. This program reads the data from the VBACAE form and produces one page per employee (additional pages as required for overflow of dependents).

Report Parameters & Filters

Report Parameters
Entity	Identify the entity you are producing 1095C forms for
Year	Identify the year that you are producing 1095C forms for
As of Date	This parameter is used to retrieve the current Assignment and Group information for an employee, as of the date provided.
Corrected	If you set this value to “Yes” then the 1095C form will be printed with the check mark on 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 this document on Page 15 in section IDIF – Defining values for the 1095C/1094C Forms and File
Hide SSN	If set to “Y” then Social Security Numbers are obfuscated with leading “X”’s
Sort By	How you want the 1095C forms to be sorted. You have these options://;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	You may use these filters to produce a subset of 1095C forms for specific employees or groups of employees.

The RB1095C will produce a PDF file that contains a 1095C form for each employee. This may be printed on blank paper, and print the instructions on the back (if printing duplex). The RB1095SM will produce a PDF file that contains a 1095C form for each employee and may be printed on the MW1095C form from RR Donnelley. This is a self-mailer form and includes the instructions pre-printed on the back.

If necessary, 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 in the VBACAE screen and produces the employer’s 1094C form, as well as the 1094C file for submission to the IRS.

NOTE: You may apply for, and receive, a Transmitter Control Code (TCC) to eFile your ACA submission. You must also submit a test form to the IRS for approval of the file format.

Report Parameters & Filters

Report Parameters
Entity	The entity code you are producing the 1094C report/file for
Year	The reporting year you are producing the 1094C report/file for
As of Date	This date is used to retrieve employee assignment and group demographic information.
Corrected 1094C	If set to YES, the data on the 1094C file is indicated as a correction
Corrected 1095C	If set to YES, the 1095C Correction indicator is turned on in the 1094C file
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 this document on Page 15 in section IDIF – Defining values for the 1095C/1094C Forms and File
Directory Name	The name of the database server-centric directory where the 1094C file will be created. The file name has a fixed name format .
Report Filters	You can use these filters to restrict the employees that are included in the 1094C report/file

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 your file is created.

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 #

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