Race to the Finish. End of Year ACA, 1095-C, 1094-C. Presented by

Transcription

1 Race to the Finish End of Year ACA, 1095-C, 1094-C Presented by Erica Hjelle, Client Manager Kristine Olson, Senior Compliance Analyst Danny Sayotovich, Development- Maintenance

2 Agenda What is the 1095-C form? Details on Part I, II, and III How does Avionté populate the form? What is the 1094-C form? How does Avionté populate the form? Running Greenshades Errors and how to fix them ACA deadlines ACA process checklist 1095 Activity

3 Disclaimer The information in this presentation is being presented by Avionté as a general informational and educational service to its clients and prospective clients. This information should not be construed as, and does not constitute, legal advice nor accounting, tax, or other professional advice or services on any specific matter. Participants should consult with their legal counsel or other professional advisor before acting on any information contained in this presentation. Avionté expressly disclaims all liability in respect to actions taken or not taken based on the contents of this presentation.

4 Welcome! It s matching game time!

5 What are the ACA reports? 1095-A: Health Insurance Marketplace statement, sent to individuals enrolled in coverage through the Marketplace 1095-B: Health insurance providers send to individuals they cover, including who was covered and when; applies to fully insured plans 1095-C: ALE s (50 or more FT or FTE) send to full time individuals with info on what coverage the employer offered; and if self-insured, who was covered and when (Part III of 1095) Had an deadline extension and asked to make good faith effort Likely no extension and increased focus on accuracy

6 What information is on the 1095? Part I: Employee Employee info and employer info Part II: Employee Offer & Coverage Line 14: what coverage, if any, offered to employee, spouse & dependents Line 15: cost of coverage offered Line 16: employer can indicate exception to a penalty; shows if enrolled in coverage Part III: Covered Individuals For self insured coverage, who was enrolled in coverage including employee, spouse, dependents

7 What does the IRS do with 1095C s? How does the IRS use this info? Helps the IRS identify full time employees and if the employer fulfilled the employer shared responsibility by offering minimum value, affordable coverage & make determinations regarding penalties. Helps the IRS identify if employees were offered affordable coverage or were eligible for coverage on the exchange.

8 1095 Part I Employee Info Pulls from: Employee > Detail Address = employee s Primary Address Employer Info Pulls from: Admin Tools > Employer > Detail Tab List of Property: GSXMLFeed_Contact_ContactName GSXMLFeed_Contact_ContactPhone

9 Part II Line 14 Avionté Logic Was the employee offered coverage? They MUST have a deduction or contribution. Did the employee enroll in insurance? This should be entered as a Deduction. Did the employee decline or waive insurance? This should be entered as a $0 Contribution.

10 Part II Line 14 Was it an ACA qualified plan? Admin Tools > Transaction Type Make sure the transaction type used is checke as Is Healthcare Don t check Is Healthcare for fixed indemnity plans, vision plans, life insurance, etc. If not ACA medical plan, don t check.

11 Part II Line 14 When was coverage offered? Alter the start and end dates of the healthcare deduction or contribution on the employee s record to reflect months of coverage or months of offer Start date = start of coverage or when employee would be eligible for coverage. End date = end of insurance coverage or when offer of coverage ends.

12 Part II - Line 15 What was the employee s cost for SELF-ONLY coverage? Enter in the amount for monthly premium for self-only MINIMUM VALUE coverage in GSACA_1095cLine15Value If not offering minimum value, leave blank. If offering MV lite or skinny plan, leave blank. If using Qualified Offer Method (1A), leave blank.

13 Part II Line 15 Avionté Logic NEW Property: Is there a max amount the employee would pay? Enter in that amount in this property, GSACA_1095cLine15UpperLimit Format is 0.00 MM/YYYY don t enter the $

14 Part II Line 16 Definitions 2A: Employee not employed during the month. 2B: Employee not full time. 2C: Employee enrolled in coverage offered. 2D: Employee in section 4980H(b) Limited Non-Assessment Period. 2E: Multiemployer interim rule relief. 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. Full definitions found here:

15 Part II Line 16 Avionté Logic

16 Part II Overrides Do you need to override the info in Part II? Go to Employee > Extra: 1095-C Line 14 Override 1095-C Line 15 Override 1095-C Line 16 Override Input code changes to cover all 12 months Use NA to indicate months that should be blank Format must be CC MM/YYYY (Lines 14 & 16) Changes in codes should be entered on a new line using Enter separation

17 Part III Only required if offering a self-insured medical plan! Did you offer a self-insured plan? Make sure property IsFEINSelfInsured = True and the transaction type of healthcare deduction(s) are checked as Is Healthcare Did dependents enroll in coverage? Dependent Info pulls from Employee > Payroll > Deduction Dependent list pulls from Deduction > Notes tab Deduction Start & End Dates = coverage dates Dependent Info should be formatted in Notes as shown:

18 1094 Logic Will auto-populate based off the number of 1095C forms that are related to the main Supplier (FEIN) Will check Yes if multiple FEINS are identified amongst the control group. Controlled by property ACA_SupplierGroupingNumber Controlled by Property GSACA_1094cLine22Options.

19 1094 Logic Part III Was MEC offered for this month? Looks at property ACA_EEN_MEC_Date & if ACA_EEN_MEC=True # of employees eligible for insurance at any point during the month; looking at Effective Insurance Dates to determine full-time status as well as the employee's ACA Eligibility being set to Yes # of employees who have an active Assignment and not terminated as of the first day of the month. Any employees who were considered full-time during the month whether or not they had an assignment during the aforementioned period.

20 Running Greenshades 2 1 Weekly Process > Generate Greenshades

21 Running Greenshades Select Supplier, Year, and Q4 ACA In the file info section, choose your designated folder to store the XML file on your local drive. Click Generate Feed & XML Review & correct any severe errors 1 2 3

22 Greenshades Errors If you have severe errors, you must correct. Correct, then click on Generate Feed & XML. If you only have warnings, you can bypass after you review. You can close the Greenshades box, then click on Generate XML. If you need to make adjustments to fix the warnings, make the changes and then click on Generate Feed & XML.

23 Greenshades Errors Most severe errors are due to incorrect property set up due to wrong values being entered or entered in the wrong format. Not all combinations are valid. If you get Greenshades errors, review the following properties: - ACA_EEN_MEC : are you offering minimum essential coverage? True/False - ACA_EEN_MVP: are you offering minimum value plan? True/False - GSACA_1095CLine14Value: which code applies to your plan? CC MM/YYYY - GSACA_1095CLine15Value: monthly cost of self-only minimum value plan, if applicable - GSACA_1095CLine16Value: did you use an affordability safe harbor? CC MM/YYYY - GSACA_1094CLine22Options: does transition relief apply? A, B, C, or D or combination ***For a complete list, see the ACA Process Guide***

24 Greenshades Overview Run Greenshades Weekly Process Resolve severe errors Review warnings Run Avionte 1094-C & 1095-C reports Audit report Make corrections as needed Re-run Greenshades Weekly Process Resolve severe errors Review warnings

25 1094-C/1095-C Deadlines Dates to know: Jan 31 st : 1095-C provided to employees Feb 28/29 th : paper copies, 1094-C and C s filed with the IRS March 31 st : electronically filed, 1094-C and 1095-C s with the IRS. Must file electronically if more than C s.

26 Year End ACA Checklist Annually: Import Year End enrollment and declination data & dependent information from insurance providers (if applicable) Review ACA end of year properties Run Employee Deduction/Contribution List AQ to verify deduction and contribution data entry Run ACA Census AQ and do final verification of employee eligibility Run Greenshades Weekly Process then run Avionté 1095-C report Audit/review 1095-C reports Make 1095-C corrections as needed Re-run Greenshades Weekly Process & re-run 1095-C report Print mailing labels using Avionté 1095c Label (if mailing inhouse)

27 1095 Activity John Doe John Doe: What does his look like? o John is a variable hour employee that will be measured using the look back method. o John was hired on July 1, 2014 & has a 12 month measurement period. o His admin period is 30 days. o At the end of his measurement period in 2015, John met the hours requirement and is considered full time. o John was offered fully-insured MVP insurance, including his spouse and dependents, which is Line 14, code 1E. o His rate is $ per month for self-only coverage or $ for family coverage. o His rate is affordable based on his rate of pay. o John and his spouse and dependents did not enroll.

28 John was in initial measurement or in an admin period thru July 2015, so in Line 14 he is a 1H (not offered coverage) and Line 16 is 2D (limited non-assessment) Activity John Doe John was offered coverage to himself, spouse & dependents, which is code 1E for Line 14. Line 15, his rate was $ for selfonly coverage. Line 16 is 2H as his plan is affordable based on his rate of pay.

29 John Doe Contribution Set Up 1. John declined coverage enter as a $0 Contribution in Avionté. Go to Employee>Payroll > Contribution. 2. He was in his admin period in July and we offered him insurance during this month. He could be on insurance immediately, but declined coverage July 10. Start date = July 10, As of December 31 st, John is still working and has still declined insurance. End date = blank

30 1095 Activity Jane Doe Jane Doe: What does her look like? o Jane is hired as a full time/non-variable employee on April 1, o Her admin period is 90 days. o Jane was offered self-insured MVP insurance, including her spouse and dependents. o Her rate is $ per month for self-only coverage or $ for family coverage. o Her rate is affordable based on her rate of pay. o Jane enrolls herself, husband and son in insurance starting July 1,2015. o Jane stops working and terminates employment on Dec 14,2015.

31 1095 Activity Jane Doe Jane was hired in April, so no offer of coverage was made in Jan-March, code 1H in Line 14 & 2A in Line 16. Jane was in admin period April- June, so in Line 14 she is a 1H (not offered coverage) and Line 16 is 2D (limited non-assessment). Jane is enrolled in self-insured coverage so Part III must list the enrollees & the months they had even 1 day of coverage. Jane was offered MVP coverage to herself, spouse & dependents, which is code 1E for Line 14. Line 15, her rate was $ for self-only coverage. Line 16 is 2C as she enrolled in coverage. Jane terminates 12/14. Since she did not have coverage the full month, Line 14 is code 1H and Line 16 is code 2B

32 Jane Doe - Deduction 1. Jane enrolls in coverage enter in a deduction. Go to Employee > Payroll > Deduction 2. Jane s insurance took effect July 1 st. Start date = July 1, Jane terminated Dec 14 th and her insurance was effective 1 more week. End date = Dec 20, 2015 Enter start date & make sure to enter end date when insurance coverage ends. Make sure to enter in dependent information in Deduction > Notes.

33 1095 Activity Jennifer Doe Jennifer Doe: What does her look like? o Jennifer is an ongoing full time employee. o Jennifer was offered a fully insured MVP, including spouse and dependents. o Her rate is $ per month for self-only coverage or $ for family coverage. o Her rate is affordable based on her rate of pay. o Jennifer enrolls herself and her kids in her insurance plan starting Jan 1, o Jennifer stops working and terminates employment on April 9, o Jennifer comes back as a variable hour employee in August 2015 after a break in service. She will be measured for 12 month initial measurement.

34 1095 Activity Jennifer Doe Jennifer was offered & enrolled in MVP coverage starting in January, code 1E in Line 14 & 2C in Line 16. Line 15 is self-only coverage cost of $ Jennifer is rehired in Aug & in her initial measurement period & not offered coverage, so Line 14 is 1H and Line 16 is 2D. Jennifer terminates in April and did not have a full month of coverage, so Apr is 1H on Line 14 & 2B on Line 16. She is not employed May- July, so 1H on Line 14 and 2A on Line 16

35 Jennifer Doe - Deduction 1. Jennifer enrolls in coverage enter in a deduction. Go to Employee > Payroll > Deduction. 2. Jennifer s insurance took effect Jan 1 st. Start date = January 1, Jennifer terminated April 9 th and her insurance was no longer effective after that date. End date = April 9, 2015 Enter start date & make sure to enter end date when insurance coverage ends.

36 Discussion If you have any additional questions, please come visit me in the Minnesota room tomorrow!