Business Requirements Document. SR IRS Employer Reporting Requirements under the Affordable Care Act (ACA), Phase I

Transcription

1 Business Requirements Document SR IRS Employer Reporting Requirements under the Affordable Care Act (ACA), Phase I 1

2 Document Information Document Attributes ID Owner Author(s) Contributor(s) Revision History Information SR Payroll Coordination and Tax Services John Barrett Marcia Johnson Version Issue Date Changes 1 st 2/24/2014 Draft 1.1 3/25/2014 B. Burkart updates based on meeting 3/25 with John B /26/2014 B. Burkart same as 3/ /27/2014 B. Burkart continued updates, rough draft of functional requirements /17/2014 B. Burkart started updating according to the most recent information /21/2014 B. Burkart added mention of the phased approach /22/2014 B. Burkart added assumptions and outstanding items 1.7 5/1/2014 B. Burkart assumptions and outstanding items and functional requirements /9/2014 B. Burkart Worked on assumptions and outstanding items /20/2014 B. Burkart electronic consent indicator should be added to CICS and web screens /9/2014 B. Burkart updates based on 6/2 meeting /20/2014 B. Burkart updates based on last meeting with John /23/2014 B. Burkart updates based on meeting 6/23 with John /24/2014 B. Burkart moved phase II functional requirements into Phase II BRD draft /25/2014 B. Burkart functional requirements /30/2014 B. Burkart - continued functional requirements /2/2014 B. Burkart updates based on meeting 6/30/ /3/2014 B. Burkart continued 6/30 updates /22/2014 B. Burkart updates following 7/21 meeting. Revamped Functional Req /4/2014 B. Burkart updates following 7/24 meeting /7/2014 B. Burkart prepared to post the draft /16/14 B. Burkart few minor updates, replaced form with revised 1095-C /29/14 B. Burkart added outstanding question about intersection of Ken s ACA measurement process and John s ACA reporting process /30/14 B. Burkart Moved assumptions and outstanding items to Phase II BRD if isolated to Phase II /3/14 B. Burkart updates based on meeting with Legal on 11/3 Document Approvals Role Name Signature Date Controller Peggy Arrivas 2

3 Table of Contents 1 Overview Product/Solution Scope Business Services and Processes Business Rules Business Requirements Non-Functional Requirements External References How various populations will be reported

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 4980H was added by the Health Care and Education Reconciliation Act of 2010 (HCERA) that was further amended by P.L Under section 4980H, large employers (defined in section 1.1 below) must provide full-time employees with health insurance coverage or possibly face tax penalties. Failure to file properly and timely will result in return reporting penalties equal to $100 per return up to 1.5M total. The health care coverage information reporting requirements are addressed in two new IRS code sections 6055 and The information obtained from 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. 4980H 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 4980H. By the end of 2014 UC needs to have processes in place to collect the 2015 data that will be needed for reporting in early Background T.D. 9655, and the final regulations under section 4980H 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. 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 regarding 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 Employer-required Information Reporting IRC Section 6055: Information Reporting by Providers of Coverage Section 6055 is applicable to insurers, self-insuring employers, and sponsors of certain governmentsponsored programs. This section applies to both UC self-insured plans (currently CORE and UC-Care) and insurance carriers as the plan sponsors. Information reporting is required of employer-sponsored plans that provide minimum essential coverage and the furnishing to the taxpayers of a related statement covering each individual covered 5

6 under the plan, including dependents. The purpose is to determine whether an individual has minimum essential coverage or is subject to the individual responsibility penalty. Required information includes: Information about the entity providing coverage, including contact information, name, address and TIN of the employer maintaining the plan; The name of each individual, including dependents, enrolled in minimum essential coverage; The name and address of the primary insured or other related person, and The TIN and months of coverage for each covered individual. Employees who waive (opt out of) coverage are outside the scope of the Section 6055 reporting requirements. Deadline: IRS and employee statements will first be produced in early 2016 for calendar year A single 1094-C must be transmitted to the IRS (with a collection of individual 1095-C s). Statement to IRS is due on or before March 31 of year following calendar year in which minimum essential coverage was provided (for those filing electronically). (UC will file employer statements to the IRS electronically.) However, the statement to the employee is due January 31. Form: combined Form 1095-C;. Form 1095-C is the statement furnished to the covered individual 1, first due by Self-insured plans (CORE, UC-Care) complete both halves of Form 1095-C. 2 The bottom half relates to the 6055 reporting requirements. For insured plans (Kaiser, Western Health Advantage, Health Net 3 ), UC only needs to complete the top half of form 1095-C to comply with Section 6056 reporting requirements. Statement to employee: a statement to the covered individual providing the policy name, address, and a contact number for the reporting entity, and the information required to be reported is due on or before January 31 st of the year following the calendar year in which the minimum essential coverage is provided. 1 Covered individuals include both employees and their dependents. 2 Medicare PPO is also a self-insured plan. UC will need to complete both halves of Form 1095-C for Medicare PPO. However, this will be a requirement for the UCRS BRD, and is not a requirement for PPS. 3 These are the insured plans as of the 2014 plan year. The insured and self insured plans offered by UC may change over time. 6

7 Internal Revenue Code Section 6056: Reporting Requirements for Applicable Large Employers Every applicable large employer (defined under section 4980H) who employed an average of at least 50 full-time employees on business days during the preceding calendar year is required to report certain health insurance coverage information to the IRS and to furnish related employee statements to its fulltime employees. The term full-time employee means, with respect to any month, an employee who is employed on average at least 30 hours of service per week. When SR83847 is implemented, standard and initial measurement processes will be put into place. The results of those measurements will be used for the Section 6056 reporting. Required Information to be reported for Section 6056: Employer name, address, and EIN Calendar year for which information is being reported Name, address, phone #, contact person at employer (can be a third party agent) Certification as to whether the employer offered to full time employees and dependents the opportunity to enroll in minimum essential coverage by calendar month # of full time employees by calendar month during the calendar year For each full time employee, which months MEC was made available Can check a box on the form that individual was covered for all 12 months For each full time employee, the employee share of the lowest monthly premium for self-only coverage, by month. For UC, this is defined as the cost of single coverage in the Core plan. Name, address, and SSN of each full time employee (but not their dependents) and the months the employee was covered under an eligible employer sponsored plan Regulations contemplate that the IRS may permit identification of the employee using a truncated TIN on the form 1095-C rather than the SSN. Information about the employer offering coverage, including name, coverage information, date, and EIN; Deadline: No later than February 28 th (March 31 st if filing electronically) of the year immediately following the calendar year to which the return relates. Forms: 1095-C (Employee Statement) and Form 1094-C (IRS transmittal form). Must file electronically if more than 250 returns during a calendar year. Forms are currently available in draft form. 7

8 Notice to Employees: A statement (1095-C) to each full-time employee whose name is required to be set forth in the return showing the name and address of the person required to make the return (employer) and the phone number and contact person. Statement is due by January 31 st of the year following the calendar year for which the return under section 6056 is due. Self-insured plans (CORE, UC-Care) complete both halves of Form 1095-C. (Top portion of C for 6056 and bottom portion for 6055.) This project will be divided into two phases. Requirements in this BRD cover Phase I. Phase I includes all setup work that must be performed to insure that all the required 2015 data will be available for reporting in early The Phase II BRD will include the requirements for the actual reporting to the IRS and employees. 1.2 Objectives Phase I: Provide processes/methods for gathering 2015 data that will be reported in early This will become an ongoing annual process. Begin gathering data on a regular basis starting with January 2015 data. This ongoing data collection will enable annual required reporting to the IRS and employees. Phase II: Provide all information to the Internal Revenue Service and employees and their dependents included in the Affordable Care Act Employer Shared Responsibility Reporting Requirements. UC qualifies as a large employer under Code Section 4980H. The affected population for UC has been identified as follows: Active employees Non-Medicare eligible Active employees Medicare eligible Separated employees: do not report if separation date is prior to January 1 of the calendar year being reported. (e.g., in 2016, report calendar year 2015 and do not include employees separated prior to January 1, 2015.) Exception: If a separated employee was on COBRA and was covered under a self-insured plan during the reporting year, then they need to be included in the Section 6055 reporting regardless of separation date. Summary of Forms to be produced by UC: o o Form 1095-C: Employee Statement to each full time employee with contact information about employer Form 1094-C: Transmittal Form by Employer to IRS 1.3 Related Projects & Dependencies Issuance and specifications associated with Forms 1094-C and 1095-C. 8

9 Coordination with SR 83847, Affordable Care Act Benefits Eligibility Changes 2014 Section 6055 requirements impact Medicare retirees. This information would not be furnished out of PPS. It is assumed that statements for retirees would be separate from statements for employees. Medicare PPO information will need to be reported out of UCRS; this plan is not implemented in PPS. Retiree requirements would need to be addressed in a separate UCRS BRD/request that would come from the Benefit Plan Accounting department of UCOP. AYSO will require modifications in order to allow employees to opt for electronic delivery of the ACA statements. In addition, AYSO will need modifications to allow employees to view and print their electronic Form 1095-C. These requirements need to be addressed in a separate AYSO BRD. The Phase II PPS BRD will address the need to create an interface file from PPS to AYSO containing the 1095-C data. Timing of the campus s transition to UC Path could impact where the data is obtained and reported from (PPS vs. PeopleSoft or a combination of both) in the first year of reporting. UCPath: It is unclear how these statements and files will be provided for employees whose location was in PPS for part of a calendar year and in UCPath for the rest of the calendar year. R2033, SR End Benefits Last Day of Separation Month W-2 Box 12 DD process (some of the data collected for this process may be useful to this ACA project) A future BRD will address Phase II requirements for ACA reporting. 9

10 1.4 Stakeholders Acronym Description Role * Authorize Has 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 John Barrett Director X X Peggy Arrivas Controller 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 1.5 Proposed Strategy Affordable Care Act reporting requirements will be handled in two phases. Phase I will be the setup phase, where data to be tracked is identified and any data not already preserved during the reporting year will begin to be saved for later reporting. Phase II will include the actual reporting piece and has a later deadline. Phase II requirements will be in a separate BRD. 1.6 Glossary Term Description MEC Minimum Essential Coverage ALE Applicable Large Employer Form 1095-B Statement to each Covered Individual (this form is applicable to insurance carriers but generally not UC) Form 1094-B Transmittal Form to IRS (this form is applicable to insurance carriers but generally not UC) Form C Transmittal form to IRS from UC 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 10

11 Section 6056 Covered Individual Responsible Individual information return and must furnish statements to responsible individuals. 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. An individual who has minimum essential coverage. (All UC plans offer such coverage.) Under section 6055, includes employees, spouses, and dependents on the plan. The primary insured, employee, or former employee named on the application who enrolled one or more individuals in minimum essential coverage. 2 Product/Solution Scope 2.1 Included in Phase I Scope Phase I includes the setup work needed to allow UC to collect required data during 2015 (and annually thereafter) that will be reported on Form 1094-C, transmittal to the IRS, and Form 1095-C, employee statement in early (Some of the data that will be needed for the reporting in early 2016 may already be available; some may not.) 2.2 Excluded from Scope Forms 1094 B and 1095 B may be applicable to UC, in the case of former employees who separated prior to January 1 of the reporting year and fall into one of these categories: Retiree who was covered under a self-insured plan during the reporting year COBRA participant covered under a self-insured plan during the reporting year SHIP (Student Health Insurance Plan) is self-funded (self-insured) for six campuses; those locations are LA, M, SD, SF, SC, and Irvine graduate students and Hastings. The other four campuses (B, D, R, SB and Irvine undergrads) offer fully insured plans. The SHIP program director is coordinating the section 6055 reporting for the self insured plans. The insured plans will be doing the 6055 reporting for the students at the impacted locations. The population of students covered by SHIP is outside the scope of the PPS Requirements (phases I and II). The following functionality is not part of Phase I but will be included in Phase II: Producing interface files and delivering to the IRS 11

12 Producing and delivering statements for employees and other covered individuals Producing interface files and delivering to AYSO, to enable electronic delivery of employee statements Establishing employee electronic delivery consent indicator and sending to and receiving from AYSO Providing a mechanism to produce corrected forms if the original forms were incomplete or incorrect, e.g. if there was retroactive coverage, etc. Retirees are generally out of scope for both phases of the PPS project, and will be addressed by a separate BRD produced by the RASC (Retirement Administration Service Center). If the retiree was a UC employee during one or more months of the reporting year, they will receive statements out of PPS, as long as they meet other selection criteria. 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 must do Section 6055 reporting because UC has self-insured plans. Section 6055 reporting will only include: Employees and their dependents who were covered under a self-insured plan during one or more months of the reporting (calendar) year. Separated employees on COBRA who were covered under a self-insured plan during one or more months of the reporting (calendar) year. Retirees covered under a self-insured plan Covered individual refers to an individual who has minimum essential coverage. Under section 6055, covered individual for UC reporting includes employees, spouses, and dependents on the plan, retirees, and former employees on COBRA, all of whom elected one of the self insured plans. 12

13 2.3.6 For Section 6055 reporting purposes, as the plan sponsor of the self-funded plans, UC DOES need to include COBRA recipients (employees and their dependents) who are covered under a self-insured plan. An employee can be on COBRA for up to 18 months, so our responsibility may extend beyond the year of separation. Year of separation: they receive 1095-C Following years: they receive 1095-B as applicable For 6056 reporting, as an ALE, reporting for COBRA recipients is limited, as they are no longer UC employees For insured plans, the insurance carriers report under section 6055, using form B for that purpose. UC involvement is generally not required 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 Employees who do not meet ACA full time criteria (i.e. average hours per week less than 30) but who are offered benefits (this includes those who accept and those who opt out): If they are covered by a self-insured plan then we report on them for Section 6055 reporting. If not, then they are outside the scope of this project. We do not need to (and do not intend to) report on them for 6056 reporting PPS data needed to produce the reports and files will be available at run time. This includes PAR data for the reporting period Accurate and complete dependent social security number data is available in PPS (should confirm). Note that dependent information is only needed with regard to Section 6055 requirements. Thus, we will only need dependent information for the self-funded plans. The draft 1095-C form gives the option of providing DOB if SSN not available Some of the ACA reporting requires knowing whether or not an employee was offered medical benefits in a given calendar month. The employee s BELI value will be used to determine this. (BELI 1-4 or P means offered coverage. ) We will also use CTO (a title code attribute) to identify house staff; they are all offered coverage. BELI is not in the PAR. Plan to set it aside each month, maybe add to monthly maintenance The processes put into place when SR83847 is implemented will result in full time/part time designations for employees. The full time/part time designations from the standard measurement will be used in the ACA reporting for the following calendar year. No independent measurement of hours will be done solely for ACA reporting Locations will record BYH DOS code hours for all by agreement payments, so that time associated with by agreement arrangements can be included when ACA hours are counted. This includes per diem employees and resident advisors, whose hours must be counted for ACA reporting. 13

14 Postdocs: UC has no 6055 reporting responsibilities at this time, because the Postdoc plan is currently Health Net, which is not a self-insured plan. UC has 6056 reporting responsibilities for the Postdocs with 3252 title code (Postdoc - Employee), 3253 (Postdoc Fellow) and 3254 (Postdoc Paid-direct). Locations are expected to enter by agreement hours for Postdocs with 3253 and 3254 titles for use in designating them as full time or part time employees. (DOS code BYH) Medical Residents (House Staff): UC needs to include this group in ACA reporting. However, coverage data is not in PPS and will need to come to PPS from each medical school plan. Assumption: their plans are not self-insured. Assumption: UC has 6056 reporting obligations, but not Assumption: Assume they are all offered coverage. Assumption: coverage offered includes self, spouse and dependents Adjunct faculty: They will have by agreement hours, and they will be included in the reporting. They are considered full time employees who have coverage For employees who were covered during the reporting year, we will need to know which months the employee was covered; need to report as covered in a month even if only covered one day in that month Employees who are separated: 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. Example: an employee is employed at UC during January through March of 2015, working on average 30 hours/week. They would get a statement from UC for 2015, covering January through March. They would get a second statement from their new employer (if there is one) for the rest of the year. UC has a Section 6055 reporting obligation for separated employees under these circumstances: o Separated employees who had COBRA for a self-insured plan during at least one month of the reporting year o Separated employees who were covered under a self-insured plan, while employed by UC, during at least one month of the reporting year Optum behavioral health can be ignored for reporting purposes. 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 Health Net. 14

15 UC is responsible for Section 6055 reporting for retirees on self-insured plans. Year of separation: receive 1095-C out of PPS. Coded as not an employee for the months following the retirement. Coverage data from Blue Shield will be needed. Following years: receive 1095-B as applicable. This will be handled solely out of UCRS, with no involvement from PPS. Retirees covered under an insured plan: Year of separation: receive a 1095-C from UC/PPS for the months of employment and a 1095-B issued by the carrier for the remaining months of the year. Following years: receive 1095-B from insurance carrier as applicable. Assume rehired retirees will not be designated as full time by the ACA measurement processes described in SR Thus, they will not be picked up by the ACA reporting process out of PPS, unless they retired during the reporting year. 2.4 Outstanding Items ID Description As of 10/16/14, the draft forms and instructions have been received. No file layouts have been received to date. There is no word regarding the IRS timeline for finalizing the forms and instructions and providing the file layouts. For phase I, this will help us to make sure we will be able to collect and provide the right data. Also need to sort out what information goes to employee, and what information goes to the IRS. The phase II project will include the actual creation of the files and statements How will reporting be handled for LBNL? LBNL will do their own independent reporting, and not report as one of the UC ALE members in the ALE group. LBNL will need coverage data from Blue Shield for the self-insured plans. Discussions with LBNL are underway (COBRA reporting is applicable only to Section 6055) For self-funded plans Core and UC Care, we must do the reporting. UC outsourced COBRA administration to CONEXIS, so we do not have the data here. Options: Arrange with Blue Shield to produce the statements for us, or have Blue Shield send us a data file. UC and Blue Shield each need to provide pieces of the data needed to produce the 1095-C As a plan administrator, Blue Shield can do all the 6055 reporting for UC if they agree to. This would include former employees on COBRA who opted for self-insured plans, retirees on self-insured plans, and all employees covered by self-insured plans, including LBNL. (note: COBRA and LBNL data not in PPS. Data for retirees who retired prior to January 1 of the reporting year would not be in PPS. ) If Blue Shield does not agree to do this reporting, then 6055 reporting for LBNL, COBRA and retirees needs to be addressed in another way. 15

16 Assume that employees should only receive one Form 1095-C from UC (except interlocation transfers) Need a plan for reporting coverage data for medical residents. We do not have coverage data in PPS for this population: Medical Residents: o o Data file from each dean at medical schools with coverage data? Need to provide a file layout to the medical schools to communicate what we need from them. (text file) 3 Business Services and Processes N/A 4 Business Rules N/A 5 Business Requirements 5.1 User Requirements N/A 5.2 Functional Requirements Phase I Req ID Requirement Type Requirement Description Priority [L/M/H] R0001 Inventory Inventory the fields that will H need to be provided on the employee and IRS forms and files. For each field needed for reporting: o Is it needed for Section 6055 or Section 6056 reporting? (or both) This is important due to the difference in scope and purpose of the two types of reporting. Comments Dependent on the forms, instructions and file layouts from the IRS. 16

17 R0002 Data collection and planning o Is it currently available? o If available, where is it located? o If not currently available, how can it be obtained? Establish a plan for how the required data for each month of the calendar year will be tracked and collected in preparation for reporting early the following year. Implement new tracking as needed, starting with coverage offered January 1, Note that the first reporting will be generated in early 2016 for the 2015 calendar year. H If there is data we are not currently collecting, set up the means to begin collecting it starting with January Carrier files are one of the data sources currently being considered. Data to set aside each month may include hire date, separation date, BELI, BELI effective date, Primary title code, CTO, and possibly other data. BELI, BELI effective date, Primary title Code and CTO will help address the question of was the employee offered coverage that month? R0003 Dependent Reporting We will also set aside Secondary BELI qualification code and associated date. Dependents ARE included in Section 6055 reporting. H R0004 Separated Employees Dependents are NOT included in Section 6056 reporting. Employees who separated during the reporting year will be reported under Section 6055 and/or Section 6056 if they meet the other reporting requirements. H UC may still have reporting 17

18 responsibilities for employees who separated before January 1 of the calendar year being reported. See table in section 8 and sections 2.3.6, , and R0005 Scope of Section 6056 Reporting UC has Section 6056 reporting obligations for all employees who met the ACA definition of full time during at least one month of the calendar year being reported. This may include: Employees currently active Employees not currently active Employees who were covered under any UC plan Employees who were not covered under any UC plan Employees who were offered coverage and opted out H See table Section 8 R0006 Offered Coverage Offered coverage is defined as: (Benefits Eligibility Level Indicator Assigned 1,2,3,4,or P) OR Class Title Outline of the Primary Title Code is 446 (Housestaff) R0007 Full Time Definition Full time is determined by the initial measurement and standard measurement processes per SR H H From SR83847 Housestaff same as Medical Resident R0008 Data Collection - COBRA COBRA administration has been outsourced to Conexis. PPS does not have the data. A plan must be established for H Investigate obtaining data from Blue Shield on a monthly basis or once at 18

19 R0009 Data Collection Medical Residents obtaining COBRA coverage data for former employees and their dependents from Blue Shield or having the reporting generated by an entity outside of PPS. This is needed for section 6055 reporting for self-insured plans. Establish a plan for collecting and reporting data for medical residents. Medical residents are identified by CTO (Class Title Outline) of Primary Title Code 446. Coverage data: Medical Resident coverage data is not in PPS. Coordination with medical centers will be required. H the end of the year. Need to coordinate with Blue Shield. Employee and Full time/part time data from PPS and coverage data from Blue Shield must be joined together. Medical residents are coded in PPS with BELI 5, so for this population, the BELI cannot be used to determine if they were offered coverage. Offered coverage: If CTO of the Primary Title Code was 446 (Medical Resident) then assume they were offered coverage. 5.3 Reporting Requirements N/A 6 Non-Functional Requirements N/A 7 External References N/A 19

20 8 How various populations will be reported Population UC: 6055 reporting responsibility UC: 6056 reporting responsibility Comments Postdoc 3252 (employee) None Yes Postdoc 3253 (Fellow) None Yes Postdoc 3254 (Paid Direct) None Yes Medical Residents None Yes They are in PPS but their coverage data is not. Separated employee Report them if covered under a self-insured plan at least one month of the reporting year. Report them if they meet the reporting criteria during one or more months in the reporting year. e.g., they were covered during one of the months, they were considered ACA full time during one of the months being reported. Individual on COBRA self insured plan, never an employee during the year Yes No they are not employees Individual on COBRA self insured plan, was employed during the year Yes Yes Individual on COBRA insured plan, never an employee during the year No No they are not employees Individual on COBRA insured plan, was employed during the No Yes 20

21 Population UC: 6055 reporting responsibility UC: 6056 reporting responsibility Comments year Employee covered under Self-insured plan (UC-Care or CORE) Yes Yes, if considered full time for one or more months of the reporting year, or if part time and enrolled in self-insured plan. Employee covered under insured plan None Only if considered full time for one or more months of the reporting year. Employee covered under both insured plan and self-insured plan during reporting year Yes Yes Employee offered coverage and opted out No Yes, if considered full time for one or more months of the reporting year. Dependents covered under self-insured plan Yes No Employee paid over 9 or 10 months Yes, if covered by selfinsured plans Yes Employee without SSN Yes Yes default to date of birth if no SSN Dependent without SSN Yes No default to date of birth if no SSN Retiree who was an employee for part of the year Yes if he/she was covered under a selfinsured plan. Yes if they were full time during one or more of the months as an employee. 21

22 Population UC: 6055 reporting responsibility UC: 6056 reporting responsibility Comments Employees who do not meet ACA full time criteria (i.e. average hours per week less than 30) but who are offered benefits (this includes those who accept and those who opt out): If they are enrolled in a self-insured plan then we report on them for Section 6055 reporting. If not covered under a self-insured plan, then they are outside the scope of this project. We do not need to (and do not intend to) report on them for 6056 reporting. 22

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