Business Requirements Document

Transcription

1 Business Requirements Document SR Employer Shared Responsibility under the Affordable Care Act 2015 Implementation

2 Document Information Document Attributes ID Owner Author(s) Contributor(s) Information SR Esther Cheung-Hill Ken Smith Document Approvals Role Name Signature Date SR Employer Shared Responsibility 2

3 Table of Contents 1 Overview Product/Solution Scope Business Requirements Appendices SR Employer Shared Responsibility 3

4 1 Overview New monthly and annual processes for administering benefits eligibility under the Employer Shared Responsibility provision of the Affordable Care Act. 1.1 Background The Employer Shared Responsibility provision of the Affordable Care Act of 2010 requires that the UC offer medical insurance to any employee reasonably expected to have on average, 30 hours of service per week. Failure to offer coverage can result in a penalty of $2,000 times the total number of employees at the UC who have on average, 30 hours or more of service per week (approximately 130,000 times $2,000 or $260 million). The Employer Shared Responsibility provision is effective January 1, 2014, however on July 2, 2013 the IRS announced that assessment of penalties would not begin until Objectives Implement the Offer of Coverage (defined in CFR H-4(b) Offer of coverage). 1.3 Related Projects & Dependencies Prior service request SR83847 implemented the measurement and stability periods. A separate development team will address ACA requirements for UC-Path SR Employer Shared Responsibility 4

5 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 Esther Cheung-Hill X Ken Smith X Jaime Espinoza X SR Employer Shared Responsibility 5

6 1.5 Glossary Term Description CFR Code of Federal Regulations ACA Patient Protection and Affordable Care Act of 2010 ESR Employer Shared Responsibility (a provision of the ACA) Assigned BELI 1 - Full benefits 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 Hours Worked per Week (EDB 5132) meets minimum eligibility requirement. 5 - No benefits eligibility for any of the following reasons: - Average Hours Worked per Week (EDB 5132) does not meet minimum eligibility requirement - Appointments are either Casual/Restricted or are in Titles restricted to students - Appointments are Per Diem in nature - "By agreement" appointments - Appointment without salary P - Postdoctoral scholar benefits eligibility? - No value assigned or separated employee Make eligible for Medical Coverage Terminate Coverage/Deenroll Change the assigned BELI to 4. Set up the default medical enrollment (DM plan code). Process a transaction in EDB maintenance to change the assigned BELI to 5. This will result in end-dating medical, dental and vision coverage and performing other appropriate derivations. 2 Product/Solution Scope 2.1 Included in Scope 2.2 Excluded from Scope SR Employer Shared Responsibility 6

7 2.3 Assumptions & Constraints ID Assumption / Constraint In ACA processing, for finding out whether the employee is classified as Not Otherwise Offered or Otherwise Offered or Otherwise Offered without BELI P, we consider only BELI Indicator values of 1, 2, 3, 4, 5, or P. Since we do not consider BELI Indicator values of?, U, and X for the definition of the above employee classification, employees with BELI Codes with?, U, and X are indirectly excluded from ACA processing. 2.4 Outstanding Items ID Description 3 Business Requirements Overview: Once each month, report all employees having an ACA related change in eligibility, along with their mailing address so that they can be notified of the change in their status. Once each month, update benefits eligibility for any employee with eligibility changes related to their full-time status as defined in the ACA. This process will need to occur every month. Create a 31 day PIE. Rollout: The monthly reporting process described above will first run in November, The monthly eligibility update process described above will first impact eligibility as of January 1, Reporting: Two new columns are requested for the measurement outcomes report, indicating employees who have at least one pay period of 30 or 17.5 average weekly hours. Employees falling short of 30 or 17.5 average weekly hours during the measurement period, and who have no pay periods at all meeting those averages will need no additional manual review. But employees with at least one (and possibly more) pay periods that meet or exceed the average should be reviewed in case their overall average was reduced by employment breaks or special unpaid leave for which additional hours should be credited. SR Employer Shared Responsibility 7

8 PPS cannot reliably determine when employment breaks or special unpaid leave has occurred in an automated manner. For an educational institution, an employment break is any period of four or more consecutive weeks during which no hours of service have been credited. The maximum an educational institution must credit for employment breaks is 501 hours. Special Unpaid Leave is leave under FMLA, USERRA, or unpaid Jury Duty. The 13 EDB flags that highlight months in which Leaves occurred are also requested as an aid toward this assessment. 3.1 Functional Requirements NOTE: All footnotes are references for business reviewers Definitions: The following names refer to EDB or PAR data elements: Secondary BELI Status Qualification Code (EDB 0242) Secondary BELI Status Qualification Eff Date (EDB 0243) Benefits Eligibility Level Indicator Assigned (EDB 0360) Benefits Eligibility Level Indicator Derived (EDB 0375) ACA Hour of service: Paid hours as defined in the Regulations i. The definition does not align with PPS Hours on Pay Status. Full-time: This definition applies only with regard to the Employer Shared Responsibility Provision of the Affordable Care Act. Per the Regulations, Full-time is 30 ACA Hours of service per week, on average. Period: A 12 month interval of time over which average weekly ACA hours of service are determined. Standard Period: An annually recurring measurement period on a fixed schedule. Initial Period: A measurement period ending on the one year anniversary of a hire date. Employee: Any individual in PPS SR Employer Shared Responsibility 8

9 3.1.2 Secondary BELI Status Qualification Code Secondary BELI Status Qualification Code is assumed to be blank for employees who have not yet been processed in any measurement period. Code Status just prior to the effective date New status with respect to the 12 months following the effective date Typical Effective Date for this code 61 No prior ACA status. Treated as full-time based on most recent Standard Period (employee was continuing at time of implementation) 62 No prior ACA status. Treated as part-time based on most recent Standard Period (employee was continuing at time of implementation) 63 No prior status. Treated as full-time based on Initial Period 64 No prior status. Treated as part-time based on Initial Period January 1 January 1 First of 2 nd month following one year anniversary of hire date First of 2 nd month following one year anniversary of hire date 71 Treated as full-time based on Initial Period (was 63 or manually set 51) Or 99 no ACA hours 72 Treated as full-time based on Initial Period (was 63 or manually set 51) Or 99 no ACA hours 73 Treated as part-time based on Initial Period (was Treated as full-time based on most recent Standard Period Treated as part-time based on most recent Standard Period Treated as full-time based on most recent Standard January 1 Prior SBSQC plus one year. January 1 SR Employer Shared Responsibility 9

10 64) Period 74 Treated as part-time based on Initial Period (was 64) 75 Treated as full-time based on prior Standard Period (was 61, 71, 73, 76, 78) 76 Treated as full-time based on prior Standard Period (was 61, 71, 73, 76, 78) 77 Treated as part-time based on prior Standard Period (was 62, 72, 74, 75, 77, 98) 78 Treated as part-time based on prior Standard Period (was 62, 72, 74, 75, 77, 98) Treated as part-time based on most recent Standard Period Treated as part-time based on most recent Standard Period Treated as full-time based on most recent Standard Period Treated as part-time based on most recent Standard Period Treated as full-time based on most recent Standard Period Exception Codes January 1 January 1 January 1 January 1 January 1 Code Interpretation Effective Date 51 Manually treated as full-time Any 52 Interlocation Transfer- gets measured in standard measurement processes based on hire date but code will remain 52 January 1 for Standard 98 Was offered coverage. Ineligible 17.5 Hours based on most recent Standard Period January 1 99 No ACA Hours Effective Date Corresponding to the Standard or Initial Period SR Employer Shared Responsibility 10

11 3.1.3 Changes to reports created by SR83847 New Columns should be added to the reports as highlighted in Appendix 4.1 and Changes to measurement of SR83847 A new Secondary BELI Status Qualification Code 98 should be added, which means ineligible based on measuring below 17.5 average weekly hours during a standard measurement period for an employee who is otherwise offered coverage, excluding BELI P. A new constant INELIGHOURS should be established as the daily equivalent of 17.5 hours per week which is 3.5 hours. With respect to the Standard Period only, and only to employees who are otherwise offered coverage excluding BELI P, if their ACA Hours of Service are less than INELIGHOURS times DAYS then Secondary BELI Status Qualification Code should be set to 98 per the definitions above. In other words, if their ACA Hours of Service is less than FTHOURS times days, the programming would next determine if it is also less than INELIGHOURS times days. If less than FTHOURS times DAYS but not less than INELIGHOURS times DAYS the codes currently programmed from SR83847 would be used. If less than FTHOURS times DAYS and also less than INELIGHOURS times days then code 98 is used. The Secondary BELI Status Qualification Eff Date remains January 1. Selection for the Standard Period should be updated as follows: An employee should be selected for the Standard Period if the Most Recent Hire Date-EDB is on or before November 1 of last year and there is no Separation Date-EDB or Separation Date-EDB is after November 1 of last year (this is the typical case for a continuing employee). OR, if Secondary BELI Status Qualification Eff Date is on or before November 1 of last year (this would be a rehire who returned within 26 weeks and consequently is treated as a continuing employee). SR Employer Shared Responsibility 11

12 Derive SBSQC Code of 99 for zero ACA Hours calculated employees in Initial or Standard measurement, if at least 1 PAR earnings present between the employee measurement date ranges with all of the below: a CPS DOS Code value of AB, AF, or AL earnings amount is greater than zero (positive) CTO of earnings title code does not begin with 8 (University Extension) Title Code of earnings is not any of the following (Bona Fide Volunteers as previously defined in SR83847) o Student Government (Title code 4329 or 4331) o AmeriCorp Volunteers (Title code 4412) o Student Volunteer (Title code 9920) o Volunteer Clinical Faculty (Title code 2017, 2037, 2057, or 2077) Secondary BELI Status Qualification Eff Date should be updated to January 1 (Standard Period) or first of second month following (Initial Period) Definition not otherwise offered coverage An employee is assumed to be offered coverage if any one of the following conditions is met: Benefits Eligibility Level Indicator Assigned is 1, 2, 3, or P Benefits Eligibility Level Indicator Derived is 1, 2, 3, 4, or P Class Title Outline of the Primary Appointment is 446 An employee meeting none of these conditions is not otherwise offered coverage. This definition differs slightly from the one given in SR Eligible Employees Contact Info (Both Initial and Standard Periods) At the conclusion of a measurement period, any employees who have been updated to a Secondary BELI Status Qualification Code that reflects a change to full-time status (61, 63, 73, 78) or is no ACA hours code 99 and is not otherwise offered coverage should be written to the tab delimited Eligible Status Mailing File (Appendix 4.5). (For the standard measurement period ending October 31, 2015 also include codes 71 and 76 but not for subsequent years. This also applies only to those not otherwise offered coverage.) The eligible files from the various PPS instances do not need to be consolidated before being provided to the UnifyHR vendor. SR Employer Shared Responsibility 12

13 3.1.7 Ineligible Employees Contact Info (Standard Period only) At the conclusion of the Standard period, any employees who have a Secondary BELI Status Qualification Code that reflects part-time status (62, 72, 74, 75, or 77) and who are not otherwise offered coverage should be written to the tab delimited Ineligible Status Mailing File. The ineligible files from the various PPS instances do not need to be consolidated before being provided to the UnifyHR vendor. For code 72, this rule begins for stability periods starting February 1, 2016 and later (see ). Any employees who have been updated to a Secondary BELI Status Qualification Code that reflects a transition from being offered coverage to below 17.5 hours (98) should be written to the tab delimited Ineligible Status Mailing File even if they are otherwise offered coverage. (See Appendix 4.6). This rule begins with the outcome of the Standard Period ending October 31, Eligible and Ineligible Employees EDB Maintenance Any employees who have a Secondary BELI Status Qualification Code that reflects full-time status (61, 63, 71, 73, 76, 78) or No Hours status (99) and a Secondary BELI Status Qualification Eff Date equal to or preceding the first of the current month and is not otherwise offered coverage should be made BELI 4 if they are not already. A PIE ending on the Secondary BELI Status Qualification Eff Date plus 30 days should be established. Note that, if the BELI was already 4, it is preferable not to update the BELI effective date. No PIE will be forced, because the group who already had BELI 4 will be expected to go through the regular Open Enrollment process. Any employees who have a Secondary BELI Status Qualification Code that reflects part-time status (62, 72, 74, 75, 77) and a Secondary BELI Status Qualification Eff Date equal to the first of the current month and who is not otherwise offered coverage should be made BELI 5 if they are not BELI 5 already. Note that, if the BELI was already 5, it is preferable not to update the BELI effective date. For employees losing coverage at the end of a standard stability period, the BELI effective date is the same January 1 as the Secondary BELI Status Qualification Eff Date, and the medical coverage end date is December 31 of the prior year. For employees losing coverage at the end of an initial stability period (code 63 changing to 72), the BELI effective date is the first day of the 26 th month from the hire date, and the medical coverage end date is the last day of the 25 th month from the hire date. For an employee transitioning from Initial Full-time to Standard Part Time, the standard measurement process can change the Secondary BELI Status Qualification Eff Date as necessary to address ending benefits in the future at the conclusion of the initial stability period. Any employees who are otherwise offered coverage excluding BELI P and have a Secondary BELI Status Qualification Code of 98 and a Secondary BELI Status Qualification Eff Date equal to the first of the current month should be made BELI 5. This applies only to the Standard period. The BELI SR Employer Shared Responsibility 13

14 effective date is the same January 1 as the Secondary BELI Status Qualification Eff Date, and the coverage end date is December 31 of the prior year. Employees who have code 72 and SBSQC effective date equal to or preceding first of the next month should be made BELI 5 (begins in 2017, see below) BELI out of Compliance Report (PPP65xx) PPP6502 and PPP6504 should be modified so that employees with Assigned BELI 4 and Derived BELI 5, 6, 7, 8, or 9 are not reported as out of compliance Special One Time Process for employees with initial stability period beginning in 2015 and ending in 2016 Employees having a Secondary BELI Status Qualification Code of 63 (Full time Initial) or 72 should be handled the same as employees who were measured as full-time during the standard measurement period ending October 31, That is, they should be offered coverage January 1, 2016 for the entire calendar year. Their current mailing address should be written to a file that can be combined with the mailing file from the standard measurement period. SR Employer Shared Responsibility 14

15 Req ID Requirement Type Requirement Description R001 Reports PERCENT OFFERED COVERAGE on the campus compliance report (Appendix 4.2) should be rounded to one decimal place (it is currently truncated) Comments R002 Reports Employees who are separated should not be included in the report or the calculation of PERCENT OFFERED COVERAGE above. R003 Reports HOURS OF SERVICE on the Outcomes Report (Appendix 4.3) should have a numeric sign - when negative R004 Reports HOURS OF SERVICE on the Outcomes Report (Appendix 4.3) should show one decimal place and be rounded to one decimal place R005 Reports A new column AVERAGE WEEKLY HOURS of SERVICE should be added to the Outcomes Report (Appendix 4.3) This field should display one decimal place and a sign, and should be truncated rather than rounded. R006 Reports Employees who have not yet been measured should not be described as Part Time on the Campus Eligibility report. Their status may be left blank. R007 Reports The following columns should be added to the Campus Eligibility and Outcomes reports in Appendix 4.1 and 4.3 Assigned BELI Derived BELI Employment Status Hire Date Separation Date Home Department Home Department Sub-location Also for Appendix 4.3 SR Employer Shared Responsibility 15

16 30 Hour Pay Period 17.5 Hour Pay Period 13 Leave of Absence Flags R008 Control Table The CTT should be updated to change the translation for Secondary BELI Status Qualification Code 99 to No Hours R009 Data Dictionary The data dictionary should be updated to show the meaning of Secondary BELI Status Qualification Code 99 as No Hours R010 CICS Help Help for Secondary BELI Status Qualification Code 99 should show No Hours R011 Control Table A new Secondary BELI Status Qualification Code 98 should be added, which means ineligible based on measuring below 17.5 average weekly hours during a standard measurement period when the employee is otherwise offered coverage. R012 Control Table The CTT should be updated to add new Secondary BELI Status Qualification Code 98 with translation Ineligible 17.5 Standard R013 Data Dictionary The data dictionary should be updated to show the meaning of Secondary BELI Status Qualification Code 98 as Ineligible 17.5 Hours Standard R014 Help Help for Secondary BELI Status Qualification Code 98 should show Ineligible 17.5 Hours Standard R015 R016 Standard Process Standard Process A new constant INELIGHOURS should be established as the daily equivalent of 17.5 hours per week which is 3.5 hours. With respect to the Standard Period only, and only to employees who are otherwise offered coverage except BELI P, if their ACA Hours of Service are less than INELIGHOURS times DAYS then Secondary BELI Status Qualification Code should be set to 98. In other words, if their ACA Hours of Service is less than SR Employer Shared Responsibility 16

17 FTHOURS times days, the programming would next determine if it is also less than INELIGHOURS times days. If less than FTHOURS times DAYS but not less than INELIGHOURS times DAYS the codes currently programmed from SR83847 would be used. If less than FTHOURS times DAYS and also less than INELIGHOURS times days then code 98 is used. The Secondary BELI Status Qualification Eff Date remains January 1. R017 Standard Process Selection for the Standard Period should be updated as follows: An employee should be selected for the Standard Period if the Most Recent Hire Date-EDB is on or before November 1 of last year and there is no Separation Date-EDB or Separation Date-EDB is after November 1 of last year (this is the typical case for a continuing employee). The effect is to include employees with Secondary BELI Status Qualification Codes of 51, 52, 98, or 99, some of which were excluded by a rule in SR R018 Standard Process OR, if Secondary BELI Status Qualification Eff Date is on or before November 1 of last year (this would be a rehire who returned within 26 weeks and consequently is treated as a continuing employee). Derive SBSQC Code of 99 for zero ACA Hours calculated employees in Standard measurement, if at least 1 PAR earnings present between the employee measurement date ranges with all of the below: The outcome of the Standard Period should overwrite these codes too. Exception: code 52 should not be overwritten. a CPS DOS Code value of AB, AF, or AL earnings amount is greater than zero (positive) CTO of earnings title code does not begin with 8 (University Extension) SR Employer Shared Responsibility 17

18 Title Code of earnings is not any of the following (Bona Fide Volunteers as previously defined in SR83847) o o o o Student Government (Title code 4329 or 4331) AmeriCorp Volunteers (Title code 4412) Student Volunteer (Title code 9920) Volunteer Clinical Faculty (Title code 2017, 2037, 2057, or 2077) R019 Initial Process Effective date January 1 of the following year. Derive SBSQC Code of 99 for zero ACA Hours calculated employees in Initial measurement, if at least 1 PAR earnings present between the employee measurement date ranges with all of the below: a CPS DOS Code value of AB, AF, or AL earnings amount is greater than zero (positive) CTO of earnings title code does not begin with 8 (University Extension) Title Code of earnings is not any of the following (Bona Fide Volunteers as previously defined in SR83847) o o o Student Government (Title code 4329 or 4331) AmeriCorp Volunteers (Title code 4412) Student Volunteer (Title code 9920) SR Employer Shared Responsibility 18

19 o Volunteer Clinical Faculty (Title code 2017, 2037, 2057, or 2077) R020 R021 R022 Standard Standard Initial Effective date first of the second month following. At the conclusion of a standard measurement period, any employees who have been updated to a Secondary BELI Status Qualification Code that reflects a change to full-time status (61, 73, 78) or 99 no ACA hours and are not otherwise offered coverage should be written to the tab delimited Eligible Status Mailing File (Appendix 4.5). All eligible status mailing files need to be provided to the UnifyHR vendor. The files from the various PPS instances do not need to be consolidated prior to providing to the vendor. Employees should be written to the eligible status mailing file only if their assigned BELI is 5. (This is the set of employees for whom the EDB Maintenance process will change assigned BELI to 4.) For the standard measurement period ending October 31, 2015 also include codes 71 and 76 in the Eligible Status Mailing File but not for subsequent years. This also applies only to those not otherwise offered coverage. Employees should be written to the eligible status mailing file only if their assigned BELI is 5. (This is the set of employees for whom the EDB Maintenance process will change assigned BELI to 4.) At the conclusion of an initial measurement period, any employees who have been updated to a Secondary BELI Status Qualification Code that reflects a change to full-time status (63) and are not otherwise offered coverage should be written to the tab delimited Eligible Status Mailing File (Appendix 4.5). All eligible status mailing files need to be provided to SR Employer Shared Responsibility 19

20 R023 R024 R025 Standard Period Initial Period Standard the UnifyHR vendor. The files from the various PPS instances do not need to be consolidated prior to providing to the vendor. Employees should be written to the eligible status mailing file only if their assigned BELI is 5. (This is the set of employees for whom the EDB Maintenance process will change assigned BELI to 4.) At the conclusion of a standard measurement period, any employees who have been updated to a Secondary BELI Status Qualification Code 99 and are not otherwise offered coverage should be written to the Eligible Status Mailing File (Appendix 4.5) Employees should be written to the eligible status mailing file only if their assigned BELI is 5. (This is the set of employees for whom the EDB Maintenance process will change assigned BELI to 4.) At the conclusion of an initial measurement period, any employees who have been updated to a Secondary BELI Status Qualification Code 99 and are not otherwise offered coverage should be written to the Eligible Status Mailing File (Appendix 4.5) Employees should be written to the eligible status mailing file only if their assigned BELI is 5. (This is the set of employees for whom the EDB Maintenance process will change assigned BELI to 4.) At the conclusion of the Standard period, any employees who have a Secondary BELI Status Qualification Code that reflects part-time status (62, 72, 74, 75, or 77) and who are not otherwise offered coverage should be written to the Ineligible Status Mailing File. All ineligible status mailing files need to be provided to the UnifyHR vendor. The files from the various PPS instances do not need to be consolidated prior to providing to the vendor. SR Employer Shared Responsibility 20

21 R026 R027 R028 R029 Standard EDB Maintenance EDB Maintenance EDB Maintenance Exception: if they already have an assigned BELI of 5 or?, do not put them on the ineligible status mailing file. For code 72, this rule begins for stability periods starting February 1, 2016 and later (see ). Any employees who have been updated to a Secondary BELI Status Qualification Code that reflects a transition from being offered coverage to below 17.5 hours (98) should be written to the tab delimited Ineligible Status Mailing File even if they are otherwise offered coverage. (See Appendix 4.6). This rule begins with the outcome of the Standard Period ending October 31, Exception: if they already have an assigned BELI of 5 or?, do not put them on the ineligible status mailing file. Any employees who have a Secondary BELI Status Qualification Code that reflects full-time status (61, 63, 71, 73, 76, 78) and a Secondary BELI Status Qualification Eff Date equal to or preceding the first of the current month and are not otherwise offered coverage should be made BELI 4 if they are not already. Any employees who have a Secondary BELI Status Qualification Code 99 and a Secondary BELI Status Qualification Eff Date equal to or preceding the first of the current month and are not otherwise offered coverage should be made BELI 4 if they are not already. For employees satisfying R027, A PIE ending on the Secondary BELI Status Qualification Eff Date plus 30 days should be established. Note that, if the BELI was already 4, it is preferable not to update the BELI effective date. No PIE will be forced, because the group who already had BELI 4 will be expected to go through the regular SR Employer Shared Responsibility 21

22 R030 R031 R032 R033 R034 EDB Maintenance EDB Maintenance EDB Maintenance EDB Maintenance EDB Maintenance Open Enrollment process. Any employees who have a Secondary BELI Status Qualification Code that reflects part-time status (62, 72, 74, 75, 77) and a Secondary BELI Status Qualification Eff Date equal to the first of the current month and who are not otherwise offered coverage should be made BELI 5 if they are not BELI? or BELI 5 already. Note: for code 72, this logic is effective starting in Any employees who are otherwise offered coverage except BELI P and have a Secondary BELI Status Qualification Code of 98 and a Secondary BELI Status Qualification Eff Date equal to the first of the current month should be made BELI 5, using the EDB transaction process currently in place to activate deenrollment. This applies only to the Standard period. The BELI effective date for 98 is the same January 1 as the Secondary BELI Status Qualification Eff Date. For employees losing coverage at the end of a standard stability period (75) the BELI effective date is the same January 1 as the Secondary BELI Status Qualification Eff Date. For employees losing coverage at the end of a standard stability period (75) the medical coverage end date is December 31. For employees losing coverage at the end of a standard stability period (98) the coverage end date is December 31. For employees losing coverage at the end of an initial stability period (72), the BELI effective date is the first day of the 26 th month from the hire date. (Note that this practice will be effective in 2017, see R037.) SR Employer Shared Responsibility 22

23 R035 EDB Maintenance For employees losing coverage at the end of an initial stability period (72), the medical coverage end date is the last day of the 25 th month from the hire date. R036 Reporting PPP6502 and PPP6504 should be modified so that employees with Assigned BELI 4 and Derived BELI 5, 6, 7, 8, or 9 are not reported as out of compliance. R037 One time process Employees having a Secondary BELI Status Qualification Code of 63 (Full time Initial) or 72 should be handled the same as employees who were measured as full-time during the standard measurement period ending October 31, That is, they should be offered coverage January 1, 2016 for the entire calendar year. R038 Standard For employees described above, their current mailing address should be written to a file that can be combined with the mailing file from the standard measurement period. R039 All Reports (see individual reports in Appendix) Employees are reported as full-time when Secondary BELI Status Qualification Eff Date is greater than the current date (when the report is running), and Secondary BELI Status Qualification code is any one of 71, 72, 75, or 76 -or- Secondary BELI Status Qualification Eff Date is prior or equal to the current date (when the report is running), and Secondary BELI Status Qualification Code is any one of 51, 61, 63, 71, 73, 76, or 78. Note: definition has changed slightly since SR R040 All Reports (see individual reports in Appendix) Employees are reported as part-time when Secondary BELI Status Qualification Eff Date is greater than the current date (when the report is running), and Secondary BELI Status Qualification code is any one of 73, 74, 77, 78 -or- Secondary BELI Status Qualification Eff Date is prior or equal to the current date (when the report is running), and Secondary BELI Status Qualification Code is any SR Employer Shared Responsibility 23

24 R041 R042 R043 R044 All Reports (see individual reports in Appendix) All Reports (see individual reports in Appendix) Data Dictionary, CICS Help Standard measurements one of 62, 64, 72, 74, 75, 77, 98 For employees satisfying neither R039 nor R040 the status should be left blank. (52, 99, blank) Employees are reported as offered coverage when (Benefits Eligibility Level Indicator Assigned 1,2,3,4,or P ) OR Class Title Outline of the Primary Title Code is 446 (Housestaff) The definition of assigned BELI 5 must be updated. The language Average Hours Worked per Week (EDB 5132) does not meet minimum eligibility requirement should be replaced with Average ACA Hours Worked per Week from Standard Process does not meet minimum eligibility requirement Employees coded with 52 (interlocation transfer): The code should stay 52, but the SBSQC effective date should be updated. No BELI change should be made They should not appear on any mailing lists They should be included in the tab-delimited file. SR Employer Shared Responsibility 24

25 4 Appendices 4.1 Appendix A Campus Eligibility Report Tab delimited file with the following column headings and data: COLUMN HEADING Employee Number DATA Employee Number Name Employee Name Combined (EDB 0105) Status Full-time or Part-time or blank per R039, R040, and R041 Offered Coverage Status Code Status Description Status Effective Date Yes if offered coverage per R042, No otherwise Secondary BELI Status Qualification Code Code Translation from CTT Secondary BELI Status Qualification Eff Date Assigned BELI EDB 0360 Derived BELI EDB 0375 Emp Status EDB 0144 Hire Date EDB 0113 Separate Date EDB 0140 Home Dept EDB 0114 Home Dept Subloc From Department Control Table SR Employer Shared Responsibility 25

26 4.2 Appendix B Campus Compliance Report Standard PPS style formatted report such as below. Note that the totals needed for this report can be accumulated while writing the report above in Appendix A. PPPXXXX/PPPXXX /DDDDDD UNIVERSITY OF CALIFORNIA-DAVIS PAGE NO RETN: SEE RPTS DISP SCHEDULE/DIST. COMPLIANCE SCORECARD RUN DATE 12/17/14 ACA EMPLOYER SHARED RESPONSIBILITY TOTAL FULL TIME EMPLOYEES: 8082 OFFERED COVERAGE: 7821 PERCENT OFFERED COVERAGE: 96.8% SR Employer Shared Responsibility 26

27 4.3 Appendix D Outcomes Report Tab delimited file with the following column headings and data: COLUMN HEADING Employee Number DATA Employee Number Name Employee Name Combined (EDB 0105) Type Hours of Service Average Weekly Hours of Service Period Begin Date Period End Date Secondary BELI Status Qualification Code Initial or Standard Total ACA hours of service with 1 decimal and sign Average Weekly Hours of Service with 1 decimal and sign Begin date as determined by the program End date as determined by the program Secondary BELI Status Qualification Code Assigned BELI EDB 0360 Derived BELI EDB 0375 Emp Status EDB 0144 Hire Date EDB 0113 Separate Date EDB 0140 Home Dept EDB 0114 Home Dept Subloc From Department Control Table 30 HR PP Y if anywhere in the measurement period the employee had any monthly pay period with 130 or more ACA hours or any biweekly pay period with 60 or more ACA hours. N otherwise. ACA Hours should be totaled based on the combination of Pay schedule code (M for monthly or B for BW) and pay period end date to see if they meet one of the thresholds listed above. SR Employer Shared Responsibility 27

28 17.5 HR PP Y if anywhere in the measurement period the employee had any monthly pay period with 76 or more ACA hours or any biweekly pay period with 35 or more hours. N otherwise. ACA Hours should be totaled based on the combination of Pay schedule code (M for monthly or B for BW) and pay period end date to see if they meet one of the thresholds listed above. Leave of Absence Code-xxx Column Headings are: LOA CURR LOA JAN LOA FEB LOA MAR LOA APR LOA MAY LOA JUN LOA JUL LOA AUG LOA SEP LOA OCT LOA NOV LOA - DEC 13 columns containing EDB Leave of Absence Code-Current-EDB, Leave of Absence Code-January, Leave of Absence Code- February, etc. SR Employer Shared Responsibility 28

29 4.4 Appendix E Example Processing Sequence Grid Month being processed Run Date Initial Standard Oct 2014 Nov 2014 Hire date <= 11/1/2013 Period 11/1/ /31/2014 (MO) 11/10/ /8/2014 (BW) 11/1/ /8/2014 (MO changed to BW) Outcomes SBSQC 61 or 62, effective January 1, 2015 Nov 2014 Dec 2014 Hire date between 11/1/2013 and 11/30/2013 with SBSQC blank 11/10/ /31/2014 (BW changed to MO) 12/1/13-11/30/2014 (MO) 11/10/ /8/2014 (BW hired Nov 1-8) 11/24/ /22/2014 (BW hired Nov 9-22) SBSQC 63, 64 effective January 1, /8/ /6/2014 (BW hired Nov 23-30) And 6 similar permutations if changed MO to BW or BW to MO. SR Employer Shared Responsibility 29

30 Month being processed Run Date Initial Standard Period Outcomes Oct 2015 Nov /1/ /31/2014 SBSQC 63, 64 effective December 1, 2015 Oct 2015 Nov 2015 Hire Date <= 11/1/2014 SBSQC 61, 62, 71, 73, 74, 75, 76, 77,78,, 98, 99 effective January 1, , effective date is Prior SBSQC plus one year. Nov 2015 Dec 2015 Hire date between 11/1/ /30/2014 SBSQC 63, 64, 99, effective First of 2 nd month following one year anniversary of hire date. Employees with SBSQC reflecting eligibility January 1, 2016 and not otherwise offered coverage are updated to BELI 4, 31 day PIE begins January 1, 2016 SR Employer Shared Responsibility 30

31 Month being processed Run Date Initial Standard Period Outcomes Employees with SBSQC reflecting eligibility during 2015 (initial measurement period) and not otherwise offered coverage are updated to BELI 4, 31 day PIE begins January 1, 2016 Dec 2015 Jan 2016 Hire date between 12/1/2014 and 12/31/2014 SBSQC 63, 64, 99 effective February 1, 2016 Jan 2016 Feb 2016 Hire date between 1/1/2015 and 1/31/2015 SBSQC 63, 64, 99 effective March 1, 2016 SR Employer Shared Responsibility 31

32 4.5 Eligible Status Mailing File Tab delimited COLUMN HEADING DATA Client ID Value = 306 SRC LOC IMP if file produced by initial measurement process SMP if file produced by standard measurement process Two-digit UC location 01 Berkeley 02 San Francisco 03 Davis 04 Los Angeles 05 Riverside 06 San Diego 07 Santa Cruz 08 Santa Barbara 09 Irvine 10 Merced 97 ASUCLA 98 Hastings Employee Number Eligible Date Employee Number Secondary BELI Status Qualification Eff Date Exception: for SBSQC of 63 or 72 with initial stability period beginning in 2015 and ending in 2016, Eligible Date should be 1/1/16. Elig End One day short of Eligible Date + 1 year. Example: Eligible date of October 1, 2015 would have Expected Eligibility End Date September 30, Exception: for SBSQC of 63 or 72 with initial stability period beginning in 2015 and ending in 2016, Expected Eligibility End Date should be 12/31/16. Cur Elig Employee s current eligibility level based on SR Employer Shared Responsibility 32

33 assigned BELI: Full for BELI 1 Mid for BELI 2 or3 Core for BELI 4 Leave blank for any other BELI Name Employee Name Combined (EDB 0105) First Name Middle Name Last Name Employee First Name EDB0250 Employee Middle Name EDB0251 Employee Last Name EDB0252 Address 1 Address 2 City State Zip 4.6 Ineligible Status Mailing File Tab delimited COLUMN HEADING DATA Client ID Value = 306 SRC Value = SMP (The ineligible status mailing file only produced by Standard Process) LOC Two-digit UC location 01 Berkeley 02 San Francisco 03 Davis 04 Los Angeles 05 Riverside SR Employer Shared Responsibility 33

34 Employee Number 06 San Diego 07 Santa Cruz 08 Santa Barbara 09 Irvine 10 Merced 97 ASUCLA 98 Hastings Employee Number Coverage End Date Cur Elig Employee s current eligibility level based on assigned BELI Full for BELI 1 Mid for BELI 2 or3 Core for BELI 4 Leave blank for any other BELI Name Employee Name Combined (EDB 0105) First Name Middle Name Last Name Employee First Name EDB0250 Employee Middle Name EDB0251 Employee Last Name EDB0252 Address 1 Address 2 City State Zip Revision History Version Issue Date Changes 1.0 2/27/2015 Initial Version 2.0 5/1/2015 Clarifications and revisions based on initial review by PPS team and evolving business requirements /10/2015 Removed requirements related to discontinuing default enrollment SR Employer Shared Responsibility 34

35 into Core. Ending default enrollment into Core will be addressed in a separate future BRD. Added new requirement for a one time process to offer coverage January 1, 2016 to employees having an initial stability period beginning in 2015 and ending in 2016 (they were not offered in 2015 because the threshold was 70%). Added one new Secondary BELI Status Qualification Code (97) suggested by the development team. Added some columns to the tab delimited reports as suggested by a few campuses. Minor corrections here and there /30/2015 Copied and updated requirements from SR83847 that define fulltime and offered coverage columns on tab delimited reports (this also cleared up the Microsoft Word error about Reference source not found. Clarified definition of SBSQC 97 and 98 in that either is the outcome of a standard measurement period only. Added 97 to the list of codes in that should be selected into the Standard process. Deleted table in Appendix F Progression of Secondary BELI Status Qualification Code as the use of the code as grown sufficiently complex that a presentation in rows and columns is no longer effective. Removed one lingering reference to default into Core which is no longer an issue for this project. Clarified all parts of the BRD where eligibility is lost due to falling below 17.5 average hours/week that this does not apply to Postdoctoral Scholars (BELI P). Added two more columns Assigned BELI and Derived BELI to the tab delimited files at the request of the locations /20/2015 Accepted all tracked changes from Version 4.0 Clarified method of counting hours when assigning Secondary BELI Status Qualification Code 99 Clarified comparison of current date and Secondary BELI Status Qualification Code in determining current status. SR Employer Shared Responsibility 35

36 Clarifications on various transitions from one code to another. No loss of eligibility results from an Initial Period. No ineligible contact file is needed for this period. Eligible and Ineligible Contact Files are tab delimited. Other minor clean-up /28/2015 Restated selection rule for Standard Period 7.0 8/7/2015 Code 99 is zero ACA hours and at least one positive earnings record (previously was at least one non-zero). Moved rules about University Extension and Volunteers from (writing the eligible file) to (setting the SBSQC). Added lists of specific SBSQCs into paragraphs that previously only described the general case /19/15 ITS Version. Accepted tracked changes made to date. Added assigned BELI, enroll in medical coverage, and terminate coverage/de-enroll to Glossary. Secondary BELI Status Qualification Code table: Removed 99 from prior status of 61 and 62; added 99 to prior status of 71 and : Deleted redundant text re: : Changed wording about PIE they will go through regular OE if the BELI is already 4 at open enrollment time. Deleted R020 R025: Removed 63 from list R026: Removed 61, 73, 78 from list and text about standard measurement R031: clarified about PIE vs. OE R032: noted BELI 5 logic for 72 begins in 2017 R033: Added text re: EDB transaction process; clarified BELI effective dates for 75 and 98 Removed extra R034 requirement R034: Clarified timing of coverage ending for 75 and 98 R037: Added category Added R045 re: data dictionary and CICS Help updates for assigned BELI 5 description. Decided to remove 97 as a secondary BELI status qualification code from document during meeting with Ken 8/20. Deleted all text related to 97. If assigned BELI already 5, do not put on the ineligible mailing list. Added requirement about how to treat 52. Updated dates on Example Processing Sequence Grid SR Employer Shared Responsibility 36

37 8.1 8/25/15 B. Burkart updated some references. Proposed adding blank to R041. For R018 and R019, specified Standard or Initial /31/15 B. Burkart corrected dates in 4.4 and added background about the new report fields requested /3/15 B. Burkart added exception to R /11/15 B. Burkart modified R025 and mailing lists 8.5 9/23/15 B. Burkart adding additional mailing file requirements that Ken gathered from UnifyHR. 4.5 and /24/15 B. Burkart updated R025 and R026 to address an issue discovered in QA testing. We want to avoid putting employees on ineligible status mailing file if they have an assigned BELI value of? Updated R030 so BELI not changed to 5 if currently? 8.7 9/28/15 B. Burkart removed mention of BELI? and U from 3.1.5; added a mention of these codes to the assumptions section /29/15 B. Burkart updated 4.5 and 4.6 headings per programmer s suggestion. Adding location ID to eligible and ineligible files. Truncate new field in R /19/15 B. Burkart added to R017 Exception: code 52 should not be overwritten. Fixed end of November date on p /20/15 B. Burkart updates to p. 10 and R044 to remove the assumption that code 52 will be included in initial measurement. The change to the initial measurement process to include code 52 interlocation transfer may be made in a later release /27/15 B. Burkart SBSQ Code 51: updated and R027. EDB maintenance to change BELI to 4 is not applicable to code 51. Removed references to 51 in those sections. Eligible and ineligible status mailing files: do not need to be consolidated and do need to be provided to the UnifyHR vendor /3/15 B. Burkart updated report headings to make them shorter /17/15 B. Burkart removed SBSQ code 64 from and requ. 30. It is a result of initial measurement, and being coded as 64 will not result in a loss of benefits. i H-1(a)(24)(i) page 8580 SR Employer Shared Responsibility 37