Business Requirements Document. SR Affordable Care Act Reporting Phase II

Transcription

1 Business Requirements Document SR Affordable Care Act Reporting Phase II

2 Document Information Document Attributes ID Owner Author(s) Contributor(s) Information SR John Barrett John Barrett, Beth Burkart Alex Tayag, Kathy Taylor, Nadine Schumaker, Marcia Johnson Document Approvals Role Name Signature Date SR ACA Reporting Phase 2 Page 2

3 Table of Contents 1 Overview Product/Solution Scope Business Services and Processes Business Rules Business Requirements Non-Functional Requirements External References Interface File for ACA Web: Full Time Employee Chart Final 2015 Form 1095-C Form 1095-C Line 14 Codes and Meanings Form 1095-C Line 16 Codes and Meanings ow populations will be reported Report PPP7861: Employees Where 1095-C Data was Created Report PPP7862: Employees Not Eligible for 1095-C Reporting Report PPP7863: Employees Where 1095-C Line 14 Codes Could Not Be Created SR ACA Reporting Phase 2 Page 3

4 1 Overview The IRS instituted new reporting rules as part of the health care reform act, referred to as the Affordable Care Act (ACA). IRC section 4980 was added by the ealth Care and Education Reconciliation Act of 2010 (CERA) that was further amended by P.L Under section 4980, large employers (defined in section 1.1 below) must provide full-time employees with health insurance coverage or possibly face tax penalties. The health care coverage information reporting requirements are addressed in two new IRS code sections 6055 and This employer provided information will enable the IRS to identify employees who have essential minimum coverage or are eligible for such coverage through an employer. It will also give the IRS sufficient information about whether the coverage provides minimum value, as well as the cost of the coverage to the employee, in order to determine if the individual can qualify for premium tax credits or cost sharing subsidies. The information reporting required under both code sections 6055 and 6066 was initially effective for CY 2014; however, transitional relief was announced in Notice that postponed the mandatory reporting to start with CY 2015 data to be reported in early T.D. 9655, 2/10/2014, announced that the IRS issued final regulations under Code Sec on the employer shared responsibility provisions under the ACA. As summarized in a Treasury press release, the final regulations state that employers with more than 100 employees can avoid the shared responsibility penalties in 2015 by offering coverage to 70% of full-time employees. The threshold increases to 95% in 2016 and forward. Shared responsibility refers to the employer penalty for not providing coverage to full-time employees or providing coverage that is unaffordable and does not meet the minimum essential coverage required under section Background T.D. 9655, and the final regulations under section 4980 phase in the percentage of full-time workers that large employers (defined as 100 or more employees) need to offer coverage from 70% in 2015 to 95% in 2016 and beyond. SR ACA Reporting Phase 2 Page 4

5 Full-time employee is defined under the ACA as one who works 30 hours or more per week. UC, like other institutions of higher education has unique challenges related to counting the qualifying hours for certain employee classifications or volunteers. The final regulations provided clarity for the following: Volunteers: hours contributed by bona fide volunteers for a government or tax-exempt entity will not cause them to be considered full-time employees. Bona fide volunteers include any volunteer who is an employee of a government entity or an organization that is described in section 501(c)(3) that is exempt from taxation whose only compensation from the entity or organization is in the form of (i). a reimbursement for or a reasonable allowance for reasonable expenses incurred in the performance of the services by volunteers, or (ii). reasonable benefits, including length of service awards, and nominal fees customarily paid by similar entities in the performance of services by volunteers. Volunteers can be excluded from this reporting process. They will be identified by title code per the instructions in SR83847, Employer Shared Responsibility under the Affordable Care Act 2014 Implementation. Educational employees: Teachers or other educational employees will not be treated as part-time for the year simply because their school is closed or operating on a limited schedule during the summer. Resident Advisors and Teaching Assistants are not exempted and will need to have their hours of work monitored. Seasonal employees: Those in positions for which the customary annual employment is six months or less generally will not be considered full-time employees. For UC reporting purposes, it is assumed that there are no special requirements around seasonal employees. Student work-study programs: Service performed by students under federal or state-sponsored workstudy programs will not be counted in determining whether they are full-time employees. SR83847 gives instructions for excluding work study hours. Adjunct faculty: Until further guidance is provided, employers of adjunct faculty are to use a method of crediting hours of service for those employees that is reasonable in the circumstances and consistent with the employer responsibility provisions. The final regulations expressly allow a bright line test that allow crediting an adjunct with 2 ¼ hours of service each week for each hour of teaching or classroom time as a reasonable method for this purpose. 1.2 Objectives This is Phase II of the Affordable Care Act Reporting project. Objectives are as follows: Produce Section 6055 reporting (as insurer) for employees and dependents covered under UC s self-insured plans. On the Form 1095-C, this corresponds with Part III, in which coverage data is listed for employees and their covered dependents. Produce Section 6056 reporting as an Applicable Large Employer (ALE) on the Form 1095-C (R0001) SR ACA Reporting Phase 2 Page 5

6 o o Provide electronic Form 1095-C (via AYSO) to employees (print and mail vendor to provide PDF file(s) for AYSO). Provide 1095-C data and partial 1094-C data to ACA Web application (under development) for campus review before sending data to print and mail vendor, and to facilitate print and mail vendor transmittal to IRS. Deadlines: IRS and employee statements will first be produced in early 2016 for calendar year 2015, and annually thereafter. o UC will file employer statements to the IRS electronically, since it has more than 250 employees to report. IRS statements are due on or before March 31 of year following calendar year (for those filing electronically). o Employee statements are due January 31 (February 1, 2016 for 2015 reporting). SR ACA Reporting Phase 2 Page 6

7 1.3 Related Projects & Dependencies Release 2162 (SR IRS Employer Reporting Requirements under the Affordable Care Act (ACA) Phase I) implemented a new monthly process to extract information that will be used for Form 1094-C and Form 1095-C reporting processes. A new table was created in the EDB, and the following fields will be stored in the table monthly, beginning in 2015: Employee_ID ire Date Separation_Date Primary_Title CTO of Primary Title BELI_Indicator BELI_Change Date BELI_Effective_Date Secondary_Status_Qualification_Code (set by initial and standard measurement processes) Secondary_Status_Qualification_Date (set by initial and standard measurement processes) SR83847 Employer Shared Responsibility 2014 ACA: Initial and Standard Measurement processes will set the Secondary BELI status qualification code and associated effective date. This ACA reporting process will use those values to determine full time status for each reporting month. SR DOS Code for By Agreement ours on EDB SR Employer Shared Responsibility under the Affordable Care Act SR ACA Web-Review and Correct Form 1095C and Provide Interface File to Vendor (New process to interface with printing/mailing vendor). SR ACA Web-Forms 1095_ 1094 IRS Submission and Receipt Process Vendor Management negotiations with Blue Shield to satisfy Section 6055 reporting requirements for self-insured plans. Blue Shield has stated it will not do ACA reporting to the IRS and employees for selfinsured plans, but is willing to provide monthly files to UC to help us meet our obligations. UnifyR (the print and mail vendor) will be the recipient of the Blue Shield files, and will create 1095-B statements for COBRA and retirees who were covered under a self-insured plan during any part of the reporting year. Interface files from Medical Centers to provide medical coverage information for medical residents (and other identified populations), to feed into the report processing. Carrier Files monthly carrier files for the whole reporting year (the files produced by the campuses). Final forms, instructions and interface file layouts from the IRS. (see September 16, 2015 Form and Instructions for 1095-C and 1094-C) SR ACA Reporting Phase 2 Page 7

8 UCPath data conversion: UCPath will need the secondary BELI Status Qualification Code and effective date last set by the initial or standard measurement process in PPS so that they can carry the full time or part time designation forward until the next measurement process runs in UCPath. 1.4 Stakeholders Acronym Description Role * Authorize as ultimate signing authority for any changes to the document R Responsible Responsible for creating this document A Accountable Accountable for accuracy of this document (e.g. project manager) S C I Supports Consulted Informed Provides supporting services in the production of this document Provides input Must be informed of any changes Name Position * R A S C I Peggy Arrivas Controller X John Barrett Director X X Marcia Johnson Sr. Tax Analyst X Beth Burkart Sr. Business Analyst X X X Alex Tayag Programmer/Systems Analyst X X Kathy Taylor Business Analyst X X Nadine Schumaker Programmer/Systems Analyst X X 1.5 Proposed Strategy PPS will provide Form 1095-C data and partial Form 1094-C data (the total employee counts by month) to the new ACA Web application being developed. The ACA Web application will allow campus Point of Contact users to review and update the 1095-C data. (See SR101025) The ACA Web application will provide vendor files. (See SR101025) It is assumed that the vendor will handle the IRS transmittals of 1094-C data and 1095-C data in XML format. UC must provide employer contact information and EINs to the vendor for inclusion on the forms. The ACA print and mail vendor will provide printed copies of the 1095-C to employees, and also provide a PDF file of 1095-C forms to AYSO for electronic display to employees. SR ACA Reporting Phase 2 Page 8

9 Each location will report to the IRS as a separate employer using their campus FEIN on the Form 1094-C. No consolidated UC form 1094-C should be produced. When completing the ACA reporting, the secondary BELI status qualifier code and effective date set by the Initial Measurement and Standard Measurement processes will be used to determine if an employee was considered Full Time or Not Full Time during the reporting period. The ACA reporting processes described in this BRD will not do an independent determination of full time status. The following data sources will be needed to complete the ACA Reporting: o o o Current EDB (employee s current name, address information) Table PPPACA, in which monthly ACA-related data for employees for the reporting year has been stored. Coverage data will come from the following sources: Monthly Carrier files (coverage data) at the locations. External files for Medical residents and other kinds of residents whose coverage data is outside of PPS. PPS must obtain interface files from the medical centers and other sources so that coverage data for medical residents and other residents can be combined with the rest of the data for that location. Coverage data will be used in the ACA reporting process as follows: o o Part II of 1095-C form to determine if employee was covered, and if so, if they had selfinsured coverage Part III of 1095-C form, where self-insured coverage for each month is indicated for all covered individuals, including employee, spouse and dependents. The following requirements will be considered for inclusion in a later phase that will address reporting for calendar year 2016: Employees will use AYSO to opt for electronic delivery of Form 1095-C. o o AYSO should transmit employees electronic 1095-C delivery indicator to PPS in the IVR interface file. The existing data element EDB1167 will be re-purposed as the electronic delivery indicator. The default should be No electronic delivery. EDB1167 is currently sent in IVR interface C forms should be printed only for employees who have not opted to receive them electronically. (Based on electronic delivery indicator). SR ACA Reporting Phase 2 Page 9

10 1.6 Glossary Term Description MEC Minimum Essential Coverage ALE Applicable Large Employer Form 1095-B Statement to each Covered Individual (this form is used by insurance carriers to report coverage information for employees and their covered dependents. Form 1094-B Transmittal Form from insurance carriers to IRS Form C Transmittal form to IRS from UC summary of the 1095-C Form 1095 C Form 1095-C is the statement furnished to the covered individual, first due by UC must provide these statements. Section 6055 UC, as a provider of minimum essential coverage to employees, must file an information return and must furnish statements to responsible individuals. Section 6056 UC, as an applicable large employer ( ALE ), must provide information to the IRS that is used to determine if UC is offering coverage that is of minimum value and affordable. The other purpose is to determine which individuals are entitled to premium tax credits, and to provide each full time employee with a statement containing the information required. UC must make the return on a Form 1094-C and Form 1095-C. Covered Individual Responsible Individual Self-Insured Plan Insured Plan ACA Full Time An individual who has minimum essential coverage. (All UC plans offer such coverage.) Under section 6055, includes employees, spouses, and dependents on the plan, as well as former employees on COBRA and retirees. The primary insured, employee, or former employee named on the application who enrolled one or more individuals in minimum essential coverage. Self-Insured Coverage: UC assumes the financial risk for paying claims incurred by plan members, and reserves the funds necessary to pay those claims. Claims are processed and paid on behalf of UC by a third party administrator, Blue Shield of CA. Blue Shield bills UC for the cost of administration but the underlying claims are paid out of the reserve fund. Insured coverage: UC pays the carrier a premium to provide insurance coverage and to administer claims. Premium is negotiated each year, but based on UC s claims experience and actuarial calculations. The employee measured ACA full time in either the initial or standard measurement process, or they have been coded as 51 manually set to full time. 2 Product/Solution Scope Reporting needed to insure that UC is compliant with Section 6055 and Section 6056 regulations. 2.1 Included in Scope 1. Provide 1095-C data and partial 1094-C data to ACA web application (under development). 2. Establish an interface with the medical centers and other parties to obtain coverage data for medical residents and other residents whose coverage data is not housed in PPS. SR ACA Reporting Phase 2 Page 10

11 3. elped to establish an interface between Blue Shield and UnifyR to insure compliance with Section 6055 regulations for self-insured plans. (This has been handed over to Benefit Programs Vendor Relations Management to complete.) 4. Utilize the monthly carrier files to obtain the monthly coverage data that will be needed to complete the Form 1095-C. 2.2 Excluded from Scope Provide a mechanism to produce corrected forms if the original forms were incomplete or incorrect, e.g. if there was retroactive coverage, etc. (Requirements for producing corrected forms will be in a different BRD.) Forms 1094 B and 1095 B: PPS will not produce them. Reporting for retirees who retired prior to January 1 of the reporting year (retirees who retired prior to 1/1 of the reporting year and are covered under self-insured plans will be reported on a Form 1095-B produced by the Unify R vendor). Separated employees on COBRA who separated prior to January 1 of the reporting year. (Former employees on COBRA who separated prior to 1/1 of the reporting year and were covered under a self-insured plan will be handled by the Unify R vendor) Reporting of self-insured coverage following the month of separation, for employees who separated during the reporting year. This may include employees who retired or elected COBRA coverage. (UnifyR vendor to do this on a 1095-B. They were not employees at the time.) Lab Berkeley Lab data is not in PPS. The Lab s strategy regarding self-insured plan reporting is as follows: o o o The reporting for former LBNL employees on COBRA who had self- insured coverage (UC Care or CORE) will be handled by UC's third-party vendor (Unify R) on a Form 1095-B. The same applies to early LBNL retirees who are not Medicare-eligible and have selected a self- insured plan. The vendor will take data directly from the Blue Shield file. LBNL stated that they do not need to know that either the retirees or COBRA recipients were issued a 1095-B. They will assume that the "insurance company" (which in the case of UC's self-insured plans is UC because we are the plan sponsor) has assumed this responsibility. For active LBNL employees who have coverage for themselves and any dependents under a self-insured UC sponsored plan, LBNL will obtain that information directly from the Blue Shield monthly carrier files and provide that directly to the vendor ADP, who will provide ACA Employer Reporting services for LBNL. SR ACA Reporting Phase 2 Page 11

12 UCPath UCPath will have its own independent reporting process, but UCPath will need to bring over from PPS ACA related data as part of their data conversion. ACA reporting for the year a location converts to UCPath will come out of both PPS and UCPath. owever, UCPath will need to convert the current secondary BELI status qual code and effective date for inclusion in UCPath. The employee may be in a stability period at the time of conversion. Modifications to the AYSO application (handled as a separate request) to provide secondary copy of the Form 1095-C. Communications to employees regarding ACA reporting are outside the scope of this BRD. Communications may include notification about the employee statements, electronic delivery option (potentially for 2016 reporting year), etc. 2.3 Assumptions & Constraints ID Assumption / Constraint All of the plans offered by UC qualify as minimum essential coverage and minimum value The months during the calendar year for which coverage under the plan was available means The months that UC offered to full time employees a MEC plan, whether or not they accepted it UC does not have a waiting period UC is responsible for Section 6055 reporting for the UC-sponsored self-insured plans. Section 6055 reporting out of PPS can only include employees and their dependents who were covered under a self-insured plan during one or more months of the reporting (calendar) year. UnifyR will handle reporting on Form 1095-B for: Former employees on self-insured plan who either retired or elected COBRA coverage Separated employees (such as retirees) who got an extra month of coverage following separation. UnifyR will report this extra month of coverage. UnifyR will use as input to this process an interface file from Blue Shield. This interface between Blue Shield and UnifyR is being coordinated by Benefit Programs Vendor Relations Management The scope of the Section 6056 reporting is employees who were considered ACA full time for at least one month of the calendar year being reported. At the advice of outside counsel, this is being expanded to include employees who got an offer but who have not yet been measured as of the end of the reporting year, so ACA full time status is unknown. SR ACA Reporting Phase 2 Page 12

13 ID Assumption / Constraint Employees who do not meet ACA full time criteria for any months of the reporting year: If covered by a self-insured plan then we report on them for Section 6055 reporting. If covered by an insured plan, then we do not need to (and do not intend to) report on them, unless ACA full time/part time status was unknown for the entire year. If no offer or offered and opted out, UC will not report on them, unless ACA full time/part time status was unknown for the entire year PPS data needed to produce the reports and files will be available at run time. This includes: PPPACA table data. Data is being set aside monthly starting in 2015 (See SR100508). Other EDB tables Employee address, etc. 13 months of carrier files (to include adjustments). Example: reporting in early 2016 will look at carrier files from December 2014 through December Adjustments coming in in January will be too late to include in the process. Interface files from medical centers and other sources of resident data UC will need to report whether or not a full-time employee was offered medical benefits in a given calendar month. The following data will be used to determine offered coverage : The employee s BELI value (BELI 1-4 or P means offered coverage. ) CTO 446 (a title code attribute) will be used to identify house staff (medical residents), who are offered coverage outside of PPS. Some of the locations have variances on a title code basis. If a location has some title codes within CTO 446 whose employees are NOT given a qualified offer, those title codes should be put into installation dependent constants in PPS. This data is being set aside monthly as a result of release This ACA reporting process will not count hours or otherwise determine full time vs. part time status for employees. The full time/part time designation as indicated by the Secondary BELI Status Qualification Code (and effective date) set by the initial and standard ACA measurement processes will be used in this ACA reporting process. See R2151. SR ACA Reporting Phase 2 Page 13

14 ID Assumption / Constraint Postdocs: UC has no 6055 reporting responsibilities for Postdocs at this time, because the Postdoc plan is currently ealth Net, which is not a self-insured plan. The ACA Initial and Standard Measurement processes will designate the postdocs as full time or part time. The ACA reporting process will use the Secondary BELI Qualification Status Code and effective date set by those measurement processes to determine full time vs. part time status. Postdocs will be treated like other employees for the purpose of Section 6056 reporting. This population includes: o Title code 3252 (Postdoc - Employee) o Title code 3253 (Postdoc Fellow) o Title code 3254 (Postdoc Paid-direct) Medical Residents (ouse Staff) and residents of other programs: UC needs to include this group in ACA reporting. owever, coverage data is not in PPS and will need to come to PPS from another source. Assumption: their plans are fully insured, not self-insured. Assumption: UC has 6056 reporting obligations, but not Assumption: coverage offered includes self, spouse and dependents. Assumption: employee share of premium is zero or otherwise affordable AYSO will be modified to allow employees to display electronic 1095-C statements provided by the print and mail vendor. AYSO modifications will be covered by a separate BRD Secondary BELI status Qual Code 52 (interlocation transfer) should not be treated as full time for reporting purposes Medicare-eligible active employees and non-medicare-eligible active employees do not need to be treated differently for this PPS reporting process There is a need to report which months the employee was covered; need to report even if only covered one day in a month. Coverage data is needed for: Section 6055 reporting (Part III of Form 1095-C) Section 6056 reporting (Line 16, code 2C on the Form 1095-C) Locations currently (pre-ucpath) have their own unique EIN for tax reporting purposes and will be considered unique ALE members Locations in PPS for part or all of the reporting year will submit separate files to the IRS for their individual campus EINs. For the year of transition to UCPath, they would report on the months prior to conversion In UCPath, there will be only one EIN for tax reporting purposes, so only one IRS transmittal form will be produced from UCPath, and that transmittal will include data from all locations in UCPath for those months that the location was in UCPath. (Note: UCPath will use the EIN currently associated with UCOP.) For year of transition from PPS to UCPath: employees will receive two Form 1095-C s for the year of transition, one from PPS and one from UCPath. SR ACA Reporting Phase 2 Page 14

15 ID Assumption / Constraint UC has a 6056 reporting obligation for separated employees who met the full time ACA definition for at least one month of the reporting year. They would get a 1095-C statement from UC for Optum behavioral health can be ignored for reporting purposes. There is no need to report on it separately. This is because it is not the primary medical coverage; it is secondary to a medical plan coverage such as ealth Net Assume UC does not have seasonal employees; reporting requirements for seasonal employees can be ignored Rehired retirees will be treated the same way as other employees for the purpose of this ACA reporting process. (They are typically BELI 5.) Inter-location transfer: If an employee transferred to a different UC location during the reporting year (for example, from UCLA to UCI), they will receive one Form C from each location, as long as they qualify to receive a form Only adjustments up to and including December of the reporting year can be included Some of the counts reported for the 1094-C include all employees, but not all employees will receive a 1095-C. Total employee count on the 1094-C includes ALL non-separated employees, whether full time, part time or unknown. This total employee count will be supplied to the print and mail vendor by PPS via ACA Web Active employees active for the entire reporting year enrolled in a self-insured plan cannot receive both forms 1095-C and 1095-B Educational employees will be treated the same way as other employees for the purpose of ACA reporting Dual appointments assume only paid out of one of the locations, assume only benefits from one location For the 2015 reporting year, all employees will receive a printed 1095-C. For the 2016 reporting year, the electronic option may be allowed. A project may be initiated in 2016 to facilitate the electronic option. This would require a development effort in PPS and AYSO to begin in the spring We will not be able to tell if an employee is full time or part time until their first measurement, unless the code 51 (manually entered as full time) was assigned. If the full time/part time status is unknown for the entire year, we will produce a 1095-C for them, if they were offered coverage. They will also be included in full time counts. SR ACA Reporting Phase 2 Page 15

16 ID Assumption / Constraint We are not eliminating nonresident alien employees from the reporting. If they are on payroll status and are U.S. citizen, nonresident alien or resident alien we are reporting on them if they otherwise need to receive a 1095-C. Foreign residents working outside the U.S. who are employees of UC and are not US citizens or resident aliens will not be reported (Citizenship code X) Expat employees will be reported on, as they receive Blue Shield CA PPO plan UC Care (self-insured) LBNL is not an ALE member for UC reporting purposes. For our purposes, LBNL will not need anything directly from PPS. Nor will we need to pass them anything directly from the Blue Shield file Plan start month is a new field the IRS has now added to the C form. They have stated that it is optional for 2015 reporting. We will address it in We will not report the cost of the COBRA plans on line 15 for insured or self-insured for Verification of Family Member Eligibility may result in de-enrollment. If this is the case, the employee should still be treated as if they received an offer, even for the months following de-enrollment For 2015 reporting, UC s self-insured plans are Core and UC Care Residents (non-medical school): The cost to the employee of their health care coverage is assumed to be zero for calendar year 2015 reporting. If a code of 1E occurs on line 14 for one of these individuals, then PPS will put $0 into line 15 just as it would for other employees. 2.4 Outstanding Items ID Description Need to finalize plans for receiving monthly coverage data for medical and other residents from various sources at the locations. Need to finalize the interface file format, frequency and timing for the data we will receive from the data sources. Question: how will the data be transmitted to us? Is OK? Need to work out final transmission of data to the PPS technical contacts at the locations so they can upload to the mainframe where it will be accessible by PPS. 3 Business Services and Processes N/A SR ACA Reporting Phase 2 Page 16

17 4 Business Rules 1) There is no exception to the requirement to report under sections 6055 and 6056 for covered individuals who die during the year. 3) The IRS has business rules for 1095-C reporting that we need to follow. 4) For the purpose of Part III of the 1095-C, if an employee is covered for one or more day(s) in a month they are considered covered for that month. 5 Business Requirements Fulfill the Section 6055 and Section 6056 reporting requirements of the Affordable Care Act. Provide 1095-C data and partial 1094-C data to the ACA Web application (in development) to facilitate ACA reporting. 5.1 User Requirements N/A 5.2 Functional Requirements Req ID Requirement Type Requirement Description Priority [L/M/] R0001 Interface File To facilitate ACA reporting to employees and the IRS: Produce an interface file containing 1095-C data and partial 1094-C data and provide to ACA Web application in a secure manner. Comments ACA Web will create the interface files for the print and mail vendor. See attachment 8 for file layout This file should include the total employee count for the location, which will later appear on the 1094-C produced by the vendor for the IRS. SR ACA Reporting Phase 2 Page 17

18 R0002 Requirements for UC as an employer As an employer, UC is obligated to meet Section 6056 reporting requirements C is provided by an employer to its employees. For this reason, UC will complete Parts I and II of Form 1095-C for employees who were considered full time for one or more months of the reporting year. R0003 Requirements for UC as an insurer In addition, 1095-C will be produced for employees for whom the ACA status was unknown during the reporting year, but an offer of coverage was given. For employees covered under a self-insured plan, UC also has Section 6055 reporting requirements. R0004 Requirements for UC as an insurer To meet Section 6055 requirements, UC will complete Part III of Form 1095-C for employees and their dependents covered by a self-insured plan. Employees covered under a selfinsured plan for one or more months of the calendar year must receive Form 1095-C, with Parts I, II and III filled out, regardless of their full-time/part time status. R0005 Insured plans Part III of the 1095-C is only applicable to employees with self-insured plan coverage. UC will not complete Part III of the 1095-C for employees covered under an insured plan or employees without UC coverage. Part III is only completed for employees and their dependents who had selfinsured coverage for one or more months of the reporting year. Self-insured plans for active employees currently include SR ACA Reporting Phase 2 Page 18

19 R0006 Dependent Reporting Dependent reporting is only required for self-insured plans. (Section 6055 reporting) R0007 Scope Any employee who was ACA Full Time for any month during the year or covered by a self-insured plan (regardless of Full time or Part Time) for any month of the reporting year should receive a 1095-C. Core and UC Care. Insured plans currently include: Kaiser, Western ealth Advantage, ealth Net 1 ) Employees separated before January 1 of the reporting year are not included in Section 6056 reporting. R0008 Determination of full time Employees with unknown ACA FT/PT status (blank Secondary BELI Status Qual Code) for the entire reporting year who received an offer will also receive 1095-C. UC must provide Form 1095-C to employees who were considered full time for at least one month of the calendar (reporting) year. Employees with undetermined FT/PT status who received an offer may have actually qualified for ACA full time status. The secondary BELI status qualification code and date set by ACA initial and standard measurement processes should be used to determine full time for a given month. This data has been set aside in the PPPACA table. See Full Time Employee chart in the Attachment 9 for details 1 These are the insured plans as of the 2015 plan year. The insured and self insured plans offered by UC may change over time. SR ACA Reporting Phase 2 Page 19

20 R0009 Date criteria for Full Time Employee about how to determine full time. To be counted as Full Time for a month, the employee must have been employed for at least one day of the month. ire date stored for the reporting month in PPPACA is less than or = the last day of the reporting month. Make sure the employee was here during the month. AND Separation date stored for the reporting month in PPPACA is greater than or = the first day of the month or no separation date (initial values). R C Form Fields Part II (Employee offer and coverage) Line 14: Offer of coverage (enter required code). This is a required field. A code must be entered for each calendar month, even if the employee was not a full-time employee for one or more of the calendar months. See Form 1095-C Line 14 Codes and Meanings attachment for more details. For each calendar month, enter the applicable code from Code Series 1. There was a decision made not to use the optional all 12 months box, but rather to fill in the individual months. UC will use these codes on line 14 of Form 1095-C: 1A 1E 1G 1 R0011 Offer of Coverage The Benefits Eligibility Level Indicator Assigned and CTO of BELI definitions: 1 - Full benefits SR ACA Reporting Phase 2 Page 20

21 primary title code in the PPPACA table should be used to determine offer of coverage. For a given reporting month, the employee has received an offer of coverage if the following is true: Benefits Eligibility Level Indicator Assigned 1,2,3,4,or P ) OR Class Title Outline of the Primary Title Code is 446 (ousestaff) If the BELI effective date is after the first day of the reporting month, then use the prior BELI to determine whether the employee got an offer for the reporting month or not. If an employee has BELI value of? for the month of separation, then the previous month s BELI should be used for the offer of coverage determination. eligibility. 2 - Mid-level benefits eligibility - not a member of a retirement system and appointment is for 12 months or more. 3 - Mid-level benefits eligibility - not a member of a retirement system and appointment is for less than 12 months. 4 - Core benefits eligibility only - Average ours Worked per Week (EDB 5132) meets minimum eligibility requirement. P - Postdoctoral scholar benefits eligibility If no prior BELI exists (as is the case with a new hire), then the employee should default to not offered for that month. By default, CTO 446 is considered offered coverage. For any exceptions to this CTO 446 default for the reporting year being processed, those title codes should be placed in installation dependent constants. Title codes placed in installation dependent SR ACA Reporting Phase 2 Page 21

22 constants will be considered not offered coverage. For employees with primary title codes in this list of installation dependent constants, line 14 will be coded as 1. R C Line 14 Employees who received an offer of coverage for a given month will be coded as 1A, 1E or 1G on line 14. 1A for FT + offered 1A for not measured all year + offered 1E for PT + offered + opted out (see comment) 1E for PT + offered + enrolled in insured coverage (see comment) 1E for PT + offered + enrolled in self-insured coverage if they were full time during other months of the year. 1E for unmeasured, offered + insured plan, if they became PT once they are measured. 1E for unmeasured, offered + opted out, if they became PT once they are measured. 1G for never full time the whole year + enrolled in self-insured coverage one or more months 1G for unmeasured employee who later became PT + enrolled in self-insured coverage. 1G for opt out following month(s) of PT enrolled in self-insured coverage. R C Line 15 The lowest cost for single coverage is the Core self-only Note that normally we would not produce 1095-C for employee who was part time and either opted out or took insured coverage. owever, if the employee is reportable during other months of the year (e.g., had self-insured coverage or had a Secondary BELI Status Qual code that indicated full time status), then IE will be used for the part time months. Different for postdocs, see SR ACA Reporting Phase 2 Page 22

23 cost. ($0 for 2015 plan year). R0032. This goes on Line 15 of the Form 1095-C when line 14 is 1E. Otherwise it will be left blank. R C Line 14 Employees who did not receive an offer of coverage for a given month will be coded as 1 on line 14. R C Line 14 The IRS rules state that, for the purpose of line 14, we can only say there has been an offer if the employee was offered coverage every single day of the month. If the employee was hired after the first of the reporting month, then they are reported as not having received coverage for that month of hire. In this case, Line 14 will be 1 and line 16 will be 2D (limited non-assessment period). R C line 14 For the month of separation, we can assume that, for employees who got an offer, the offer was for the entire month. The month when an employee separates, coverage continues for the rest of the month. When the employee separates, their BELI becomes a "?" which would normally be considered "Not Offered". In this situation, for FT employee, 1A should be derived for line 14. If they were enrolled in coverage, line 16 would be 2C. R C Line 16 UC will use these codes on Line 16: 2A. Employee not UC provides coverage until the end of the separation month. Common combination of line 14 and 16 is 1A and 2C, for a full time SR ACA Reporting Phase 2 Page 23

24 employed during the month. 2B. Employee not a fulltime employee. 2C. Employee enrolled in coverage offered. (trumps all other applicable codes for line 16) 2D. Employee in a section 4980 (b) limited non assessment period. 2G. Section 4980 affordability federal poverty line safe harbor. employee who received an offer, and enrolled in coverage for that month. Leave line 16 blank only if none of the codes 2A, 2B, 2C, 2D or 2G is applicable. (Caution: Potential penalty situation if a full time employee did not get an offer and no safe harbor applies.) Leave line 16 blank if line 14 is 1G for all months of the year. If FT employee and no offer: 1 for line 14 and blank for line 16. These will be counted as full time employees by UnifyR, who will be doing a count of all full time employees for each 1094-C transmittal. R C Line 16 Code 2A Employee not employed during the month: Use before employee is hired and for months following separation month. Some employees, such as retirees, get an extra month of coverage (the month following the separation month). This is based on separation reason code and bargaining units. This extra month of coverage will be SR ACA Reporting Phase 2 Page 24

25 R C Line 16 Code 2B Employee not a full-time employee: Use for: PT + No offer for the reporting month PT + Offered + Opted out for the reporting month R C Line 16 Code 2C. Employee enrolled in coverage offered. (Trumps all other applicable codes for line 16) Use 2C if employee was enrolled in coverage, either insured or self-insured. Enter code 2C for any month in which the employee enrolled in health coverage offered by the employer for each (every) day of the month, regardless of whether any other code in Code Series 2 might also apply (for example, the code for a section 4980 affordability safe harbor). Do not enter 2C in Line 16 if Code 1G is entered in Line 14 for all 12 months because the employee was not a full-time employee for any months of the calendar year. In this case, we will leave line 16 blank. R0021 Medical Coverage The determination of covered status for a given month of the reporting year must take into account corrections and adjustments to prior months. Note that this is limited to reported by Unify on a 1095-B form, if they have selfinsured coverage. No penalty because we are not required to offer to Part Time employees. Carrier files will be used to determine who was actually covered in a given month. This is needed SR ACA Reporting Phase 2 Page 25

26 adjustments that have been processed before this ACA reporting is run. R0022 Medical Coverage Establish an interface with the medical centers and other entities to obtain medical residents coverage data and coverage data for other types of residents not housed in PPS. There is some risk of getting an incorrect employee ID on the incoming resident files. PPS should validate incoming employee IDs from resident files against the EDB. Incorrect IDs should be fixed before the data goes to ACA Web. The process to load the incoming resident coverage data should have both review update modes. Employee IDs in the incoming file that have no match in the EDB should be reported for campus review and action. R C Line 16 2D. Employee in a section 4980(b) limited non assessment period. Use if employee has not yet been measured in initial measurement (prior to effective date of first measurement). If Secondary BELI Status Qualification Code is blank, this indicates the employee has not yet been measured. Also use if employee was hired during reporting month, after the first of the month. (in conjunction with 1 on line 14) because of Line 16 of 1095-C, code 2C, which indicates that the employee accepted the offer of coverage. SR ACA Reporting Phase 2 Page 26

27 R C Line 16 Code 2G. Section 4980 affordability federal poverty line safe harbor R0025 Scope of Section 6055 Reporting Use for FT + Offered + Opted out. In this case, line 14 would be 1A. Section 6055 reporting applies to: employees and their dependents who were covered under a selfinsured plan during at least one month of the calendar year being reported. both full time and part time employees Self-insured plans for active employees, COBRA and non- Medicare retirees are currently Core and UC-Care but this is subject to change based on plan design in later years. R C Part III For employees covered under a self-insured plan, Part III of the 1095-C must be completed. If an employee is covered for one or more day(s) in a month they are considered covered for that month for the purpose of Part III. If completing Part III, check the Covered Individuals check box. Column A: List names of covered individuals, including the employee and dependents. Column B: SSN of each covered individual. Column C: If SSN is not available, enter date of birth Column D: Covered all 12 months. Column (d) - we will not use this column but will instead The employee was offered affordable coverage and chose not to take it. UC must comply with the Section 6055 reporting requirements because it offers self-insured plan coverage. SR ACA Reporting Phase 2 Page 27

28 check the individual boxes for each applicable month. Column E: For individuals who were covered for one or more months, information will be entered in column (e) indicating the months for which these individuals were covered. If there are more than 6 covered individuals, complete this information on the additional covered individuals on Part III Covered Individuals Continuation Sheet(s). R0027 Separated Employees Employees who separated during the reporting year will be reported for all active months under Section 6055 (self-insured) and/or Section 6056 if they meet the other reporting requirements. Employees who separated before January 1 of the calendar year being reported are excluded from the ACA reporting out of PPS for that reporting year. R0028 Citizenship Codes No ACA reporting should be done for individuals with Citizenship status code (EDB0109) X (Non- Resident Alien living and working outside the United States; wages not subject to federal and state withholding taxes). R0029 Reporting The following reports are needed out of the PPS process: List of all employees who will be receiving a C. List of all employees who will not receive a 1095-C and the reason. List of employees for whom the codes could not be derived based on the available data. Code them?? if the line 14 code cannot be derived. For foreign citizens working outside the US we do not have ACA reporting responsibility. SR ACA Reporting Phase 2 Page 28

29 o All the supporting data should be put on the report so we can see the background data. Count total number of 1095-C to be produced. (This will be included in the statistical reports that are generated when PPS produces the file for ACA Web.) These reports should be in Excel format. Campuses can use these reports to assist with the validation of their 1095-C data. R0030 Error Processing If for any month, a code for line 14 could not be derived, a record should still be sent in the ACA Web interface file so that the campus can fill in the gaps using the ACA Web user interface. R C line 14 Line 14 should not contain both 1G and 1A for a reporting year for one individual. This is because 1G means they were never full time during the reporting year. R0032 Postdoc Line 15 values If a 1E is derived for a Postdoc then for 2015 these costs should be entered on line 15: If plan is P1 (MO) then self-only coverage employee cost is $ If plan is P2 (PPO) then self-only coverage employee cost is $ Post processing will convert the 1G to 1E for this situation. 5.3 Reporting Requirements N/A SR ACA Reporting Phase 2 Page 29

30 6 Non-Functional Requirements N/A 7 External References Document Location Author 2015 Instructions (Form) IRS for Forms 1094-C and 1095-C (Instructions) Business Rules lopers/information_returns/air_businessrules_ty20 15v1.0.zip IRS ACA Reporting Scenarios 1095-C SharePoint Business Sponsors ACA Reporting Analysis Team SR ACA Reporting Phase 2 Page 30

31 8 Interface File for ACA Web: 1095-C Part I and II Field Description Length Location Code 2 Employee-ID 9 Reporting Year 4 SSN 9 Name 30 First Name 30 Middle Name 30 Last Name 30 Name Suffix 4 Address Line 1 30 Address Line 2 30 Address City 21 Address State 2 Address Zip Code 9 Foreign Address Indicator 1 Foreign Country 2 Foreign Country Name 30 Foreign Province 15 Foreign Postal Code 10 LINE14-CD-JAN 2 SR ACA Reporting Phase 2 Page 31

32 LINE14-CD-FEB 2 LINE14-CD-MAR 2 LINE14-CD-APR 2 LINE14-CD-MAY 2 LINE14-CD-JUN 2 LINE14-CD-JUL 2 LINE14-CD-AUG 2 LINE14-CD-SEP 2 LINE14-CD-OCT 2 LINE14-CD-NOV 2 LINE14-CD-DEC 2 LINE15-PREMIUM-JAN 7 LINE15-PREMIUM-FEB 7 LINE15-PREMIUM-MAR 7 LINE15-PREMIUM-APR 7 LINE15-PREMIUM-MAY 7 LINE15-PREMIUM-JUN 7 LINE15-PREMIUM-JUL 7 LINE15-PREMIUM-AUG 7 LINE15-PREMIUM-SEP 7 LINE15-PREMIUM-OCT 7 LINE15-PREMIUM-NOV 7 LINE15-PREMIUM-DEC 7 LINE16-JAN 2 LINE16-FEB 2 LINE16-MAR 2 SR ACA Reporting Phase 2 Page 32

33 LINE16-APR 2 LINE16-MAY 2 LINE16-JUN 2 LINE16-JUL 2 LINE16-AUG 2 LINE16-SEP 2 LINE16-OCT 2 LINE16-NOV 2 LINE16-DEC 2 SELF-INS-BOX 1 ome Dept 6 ome Dept-Sub Location 2 Primary Title 4 SR ACA Reporting Phase 2 Page 33

34 1095-C Part III Field Description Length Location Code 2 Employee ID 9 Reporting Year 4 Covered Individual # 2 Covered Individual SSN 9 Covered Individual Name 30 Covered Individual Birth Date 10 Covered Individual Relationship Code 1 Coverage Indicator Jan 1 Coverage Indicator Feb 1 Coverage Indicator Mar 1 Coverage Indicator Apr 1 Coverage Indicator May 1 Coverage Indicator Jun 1 Coverage Indicator Jul 1 Coverage Indicator Aug 1 Coverage Indicator Sep 1 Coverage Indicator Oct 1 Coverage Indicator Nov 1 Coverage Indicator Dec 1 SR ACA Reporting Phase 2 Page 34

35 9 Full Time Employee Chart Employees with the following combinations of Secondary BELI Status Qualification Code and Secondary BELI Status Qualification Code Effective Date for the calendar (reporting) month will be considered full time for that month as long as they were employed at least one day of that month: Secondary BELI Status Qual Code (from PPPACA for reporting month) Secondary BELI Status Qual Code Definition (From SR83847) Full Time Logic 51 Full time (manually set) Treat code 51 as full time if: Sec BELI Status Qual Code Effective Date is on or before the last day of the reporting month. 61 Full-time Standard (No prior status) Typical effective date is January 1 Treat code 61 as full time if: Secondary BELI Status Qual Code Effective Date is on or before the last day of the reporting month (they were considered full time for at least one day in the reporting month) 63 Full-time Initial (No prior status) Typical effective date: First day of 2nd month following one year anniversary of hire date 71 Full Time Initial to Full Time Standard Typical effective date is January 1. Treat code 63 as full time if: Sec BELI Status Qual Code Effective Date is on or before the last day of the reporting month. (they were considered full time for at least one day in the reporting month) Always considered FT. Sec BELI Status Qual Code Effective Date is not a consideration. (they are going from FT to FT) SR ACA Reporting Phase 2 Page 35

36 72 Full Time Initial to Part Time Standard Typical effective date is January 1. Treat as Full Time if Secondary BELI Status Qual Code Eff Date is after the end of the reporting month. 73 Part Time Initial to Full Time Standard Typical effective date is January 1. Treat code 73 as full time if: Sec BELI Status Qual Code Effective Date is on or before the last day of the reporting month (Considered full time for at least one day of the reporting month.) 75 Full Time Standard to Part Time Standard. Typical effective date is January Full Time Standard to Full Time Standard Treat as Full Time if Secondary BELI Status Qual Code Eff Date is after the end of the reporting month. Considered FT regardless of effective date Typical effective date is January Part Time Standard to Full Time Standard Typical effective date is January 1. Treat code 78 as full time if: Sec BELI Status Qual Code Effective Date is on or before the last day of the reporting month Considered full time for at least one day of the reporting month. 99 No ACA ours If Secondary BELI Status Qual Code effective date is on or before the last day of the reporting month, then the employee is considered NOT full time for that month. Special logic for November and December 2015: If Secondary BELI Status Qual Code effective date is after 12/31/15, then the ACA SR ACA Reporting Phase 2 Page 36

37 reporting process should use the October 2015 value of Secondary BELI Status Qual Code to determine full time status. 2 Code 52 interlocation transfer is not counted as full time. 2 This logic will need to be revisited for 2016 ACA reporting. The SBSQC of 99 does not have an implied prior value. This has an impact on ACA reporting when the effective date is after the reporting month. SR ACA Reporting Phase 2 Page 37

38 10 Final 2015 Form 1095-C SR ACA Reporting Phase 2 Page 38

39 SR ACA Reporting Phase 2 Page 39