Managed ACA IRS Reporting Frequently Asked Questions

Transcription

1 Managed ACA IRS Reporting Frequently Asked Questions Section 6055 and 6056 Reporting FAQs Calendar Year 2015 Page 1 - Next Generation Enrollment, Inc. Proprietary Business Information

2 Table of Contents Data Templates How do I report an employee who transferred between entities/employer Identification Numbers during the calendar year? How do I report an employee who changes from full-time to parttime during the calendar year? How do I report an employee who changes from part-time to fulltime during the calendar year? How do I report employees across multiple EINs? What do I enter in the EECost field? Is this the employee share, employer share or both? How do I report the COBRA employee cost? We have retirees over age 65 (Medicare primary) on our coverage. Do I need to report these employees on the data files? If a retiree is over 65 and Medicare is primary, but spouse is under 65 and employer coverage is primary, how should the spouse be reported? How do I code retirees and COBRA participants that pay 100% of the premium under the Affordability Safe Harbor? On the catch-up files, do I need to duplicate all data for each month or can I place a record on the file once and indicate it should apply to all months? Page 2 - Next Generation Enrollment, Inc. Proprietary Business Information

3 General Questions How do I know if I am considered an Aggregated Applicable Large Employer Group? Intake form Is a school district considered a governmental unit? Page 3 - Next Generation Enrollment, Inc. Proprietary Business Information

4 How do I report an employee who transferred between Employer Identification Numbers (EINs) during the calendar year? For the month of transfer between EINs the employee will be reported under whichever EIN they worked the most hours for in that month. In the Employee Census file provide a termination date to indicate the last day of the month the employee should be reported under the EIN they are transferring from. This date should be the last day of the last month they would be reported under the old EIN. o Example: If an employee transfers between EIN1 and EIN2 on May 28, 2015, for the months January through May report the employee under EIN1, and for June through the remainder of the year report the employee under EIN2. In the report for May provide a termination date of May 31, In the Employee Census file provide a hire date to indicate the first day of the month the employee should be reported under the EIN they are transferring into. This date should be the first day of the first month they would be reported under the new EIN. o Example: Using the above situation, for the months of June through the remainder of the year provide a hire date of June 1, The eligibility date in the employee census file should remain the same throughout the reporting, unless the employee actually experienced a change in eligibility resulting in a new eligibility date and new waiting period. The eligibility date remaining the same will allow the system to see that the employee experienced a change in EIN but not subject to a new hire waiting period to ensure the appropriate Series 1 and 2 codes are calculated. o Example: Using the above situation, if the employee was originally hired as full-time into EIN1 on October 2, 2014 their eligibility date should remain October 2, 2014 for all months of the year (unless they Page 4 - Next Generation Enrollment, Inc. Proprietary Business Information

5 actually experience a change in status that results in a new waiting period). How do I report an employee who changes from full-time to part-time during the calendar year? If the employee is in a stability period as full-time when they experience a change in status to part-time, they should be reported as F for all months of the calendar year in which they are in a stability period. If the employee loses eligibility due to the change in status to part-time where they no longer receive an offer of coverage, report the employee as F for the months they are eligible as full-time and report them as a P for the months their eligibility ends due to an end in the stability period/eligibility. Eligibility Date should remain as their full-time eligible date. How do I report an employee who changes from parttime to full-time during the calendar year? The employee should either not be included on the census files for the months they were part-time, or they can be included with the employment level of P for the months they were part-time. If they are included in months they were part-time their eligibility date should reflect the date of the change in status to full-time. For the months after the change in status the employee should be reported with an employment level of F with an eligibility date reflecting the date of the change in status. The waiting period type and waiting period dates should reflect the waiting period applied to that individual after the change in status. Page 5 - Next Generation Enrollment, Inc. Proprietary Business Information

6 How do I report employees across multiple EINs? The employee should be reported under the EIN at which they were employed for each individual month. If an employee moves from EIN to EIN within the company, use the last noted EIN for the month reporting. What do I enter in the EEcost field on the Employee Census file? Is this the employer share, employee share or both? For EEcost, you should report the lowest employee share of premium on the least expensive employee only minimum essential coverage plan offering. Only report the employee share of the premium. How do I report the COBRA plan cost? You should report the lowest employee only premium on the COBRA offerings. Be sure to include the 2% administration fee in the amount. We have retirees over age 65 (Medicare primary) on our coverage. Do I need to report these employees on the data files? Where Medicare is primary, you do not need to report your retirees. If a retiree is over 65 and Medicare is primary, but spouse is under 65 and employer coverage is primary, how should the spouse be reported? You will report the retiree on the Employee Census File and the spouse on the Coverage file. The retiree s SSN will link the spouse to the correct record. Page 6 - Next Generation Enrollment, Inc. Proprietary Business Information

7 How do I code retirees and COBRA participants that pay 100% of the premium under the Affordability Safe Harbor? You will choose option 4 to indicate no safe harbor was used for COBRA participants. On the catch-up files, do I need to duplicate all data for each month or can I place a record on the file once and indicate it should apply to all months? The RAFT tool has to have data for each individual month. This is how the codes are calculated. If an employee was employed through October, they will have 10 different records, one for each month. If you use the monthly template instead of the catch-up template, you could reuse the same file for each month and just add new hires or and make any demographic changes. How do I know if I am considered an Aggregated Applicable Large Employer Group? An Aggregated Applicable Large Employer Group refers to a group of Applicable Large Employer Members treated as a single employer under section 414(b), 414(c), 414(m), or 414(o). An Applicable Large Employer Member is a member of an Aggregated Applicable Large Employer Group for a month if it is treated as a single employer with the other members of the group on any day of the calendar month. If an Applicable Large Employer is made up of only one person or entity, that one Applicable Large Employer Member is not a part of an Aggregated Applicable Large Employer Group. Government entities and churches or conventions or Page 7 - Next Generation Enrollment, Inc. Proprietary Business Information

8 associations of churches may apply a reasonable, good faith interpretation of the aggregation rules under section 414 in determining their status as an Applicable Large Employer or member of an Aggregated Applicable Large Employer Group. To view Title 26 Section 414 of the IRS Code, go to: title26-subtitleA-chap1-subchapD-partI-subpartB-sec414.pdf Is a school district considered a governmental unit? A Governmental Unit is defined as the government of the United States, any State or political subdivision thereof, or any Indian tribal government (as defined in section 7701(a)(40)) or subdivision of an Indian tribal government (as defined in section 7871(d)). Page 8 - Next Generation Enrollment, Inc. Proprietary Business Information