Year-End ACA Processing 2017

Transcription

1 Year-End ACA Processing 2017 * * PERSONA * * applied systems technology TECHNICAL DOCUMENT 1

2 ***** Major Announcement regarding submittal of electronic ACA files to IRS. ***** AST will not be supporting the direct filing of ACA information from Persona to the IRS. The IRS makes this process nearly impossible for a small company like ours to manage. Last year, several clients got dangerously close to being fined due to communication issues with the IRS. You can still print the 1095c s and 1094c from Persona. However, electronic filing of ACA data must be handled by Solv (formerly known as IBF). You are in good hands with Solv. Please contact them at Overview of the ACA Year-End Process: The following provides an overview of the ACA year-end processes in your Persona package. Please read all the instructions before beginning closings. Remember to always check which company that you are in before proceeding, look at the top of your Menu in the title bar to verify your company ID Task 1. Create your Year-End Companies according to the AST Year-End Document. Which Year-End Task Description Back up your data and create a year-end company to run year-end reports. Absolutely make a complete BACKUP of all data files AND VERIFY IT before doing year-end closings. 2. On 12/31/17 make a copy of your ACA file. Live Run PR to copy your most current ACA file to your year-end company. 3. Update ACA Control if Eligible for Non-Calendar Relief Year-End Go to PR Pull up the *DEFAULT* record and all other relevant records and reference field Build Initial 1094-C Workfile Year-End Run PR applied systems technology TECHNICAL DOCUMENT 2

3 Task Which Task Description 5. Build 1095-C Workfile Year-End Run PR Print 1095-C Edit List (Optional) Year-End Run PR Edit 1095-C Workfile (if needed) Year-End Run PR Print 1095-C s Year-End Run PR Print to a pre-printed 1095-C. 9. Print 1094-C (if needed) Year-End Run PR Print your 1094-C if desired. If you electronically file ACA data to IRS you don t need a printed 1094-C (however you may want to preview before electronically filing). 10. Create ACA Electronic Submittal files for Solv Year-End Run PR The step will create files for Solv to transmit to IRS for you. You will need to run these steps for each payroll EIN you run. Note that steps 1 and 2 are fully described in the Year-End Processing 2017 document. This ACA Year-End Processing guide will start at step 3. Note to reference instructions for these forms, see applied systems technology TECHNICAL DOCUMENT 3

4 Step 3 Update ACA Control Record if eligible for 2017 Non-Calendar Relief Some employers with non-calendar year plans may be eligible for ACA Non-Calendar Relief (note AST cannot help you determine if you are eligible for this relief or not). If you are eligible, you must update the ACA Control Record PR to tell the system which class employees are eligible for this relief, and which months of 2017 are eligible. First, go to PR If the non-calendar relief is for all classes of employees (or if you only have the *DEFAULT* record in this file, you can pull up the *DEFAULT* record and edit field 13 to be Yes. The months considered for non-calendar relief will be those prior to the start of the plan year as set in field 5. If the non-calendar relief is for only a certain class of employee, do the same as above, but only for the relevant Class Code. An example of this is where your Temps are on a Jan-Dec plan year, but office staff is July-June. applied systems technology TECHNICAL DOCUMENT 4

5 Step 4 Build Initial 1094-C Workfile This step will create the initial data for your 1094-C. Run PR Print Screen is below: Fields 1-8 will default from the company setup in XX for the current company you are in. Fill in field 9 ONLY if you run payroll in multiple EIN s, and those EIN s are part of the same Aggregated ALE Group for ACA purposes. You can reference either the live company or yearend company for each EIN. Enter through field 10, transmitter control code and field 11, IRS software ID. Adjusting this field is not necessary as Solv will be submitting the files to the IRS for you. applied systems technology TECHNICAL DOCUMENT 5

6 Step 5 Build the 1095-C Workfile This step will create the initial data for your 1094-C. Run PR You will be asked the following: 1) ACA Data Year to Process a. Note the current year of your year-end company defaults. 2) Do you want to run the ACA Measurement Update Utility? (Note depending on timing this question may not come up). a. This requires a Yes answer to continue. It runs the PR update to set any final breaks-in-service to the ACA measurement records, if needed. An error report may open in Excel. If any insurance offer records are coded as 1G but the insurance was not self-insured, this needs to be manually fixed. Also if any insurance records are coded as 1G but the employee was Full-Time for any part of the year, this needs to be manually fixed. To manually fix you should: 1) Change the insurance IRS code in PR field 15 to be correct; once these are done, 2) Rebuild the 1095-C workfile by running PR again. NOTE: If you run the Build 1095-C Workfile again, you will first be asked to rebuild the existing 1095-C workfile. A Yes answer deletes all the previous 1095-C workfile records first, then rebuilds the 1095-C records. If you made any manual changes to the 1095-C workfile records, this step will delete all those manual changes. applied systems technology TECHNICAL DOCUMENT 6

7 Step 6 Print 1095-C Edit List (Optional) This step prints an edit listing of the 1095-C workfile records. You can run for a range by Branch, by Class code, and/or specific employee. applied systems technology TECHNICAL DOCUMENT 7

8 Step 7 Edit 1095-C Workfile This step will allow you to edit the 1095-C workfile. Below is a print screen. Note in the appendix to this document is an explanation of the IRS codes for each box. Note the Full-Time check box is not transmitted to the IRS. This code is for Persona use only, but indicates that from the ACA measurement record the person was marked Full-Time for at least one day of employment in the reporting year. applied systems technology TECHNICAL DOCUMENT 8

9 Step 8 Print the 1095-C s If Solv is printing 1095c s for you, then you do not need to do this step. The files for Solv are created in Step 10. Print options will be: Print Sequence (SS# or Name) SS#/Name hit <enter> to print everyone, or use the lookup to print a single form. Corrected Y/N. ONLY check this Yes if you are reprinting a 1095-C that was both changed, AND had already been filed by the employer to the IRS. o Do not check Corrected if the 1095-C had been changed, given to the employee, but not yet filed by the employer to the IRS. Void Y/N. Only check this Yes if you are voiding a previously printed 1095-C that had already been submitted by the employer to the IRS. Printer Choices The printout to the landscaped 1095-C form requires complicated initialization strings sent to your printer. Depending on your printer type you may find some Persona print definitions fit the form better than others. When printing, choose the Output Options Menu to select an Alternate Printer. Your Persona system has been setup with 3 new printer records: ACA1, ACA2, and ACA3. Feel free to try each one to find the one that most closely lines with the 1095-C form. Note when doing such a test, choose to print a single 1095-C (rather than the whole batch) using the lookup at the SS#/Name. Should ACA1, ACA2, or ACA3 not appear in your printer listings, or the forms not line up using any of the definitions please contact AST Support. applied systems technology TECHNICAL DOCUMENT 9

10 Step 9 Print the 1094-C The 1094-C is your summary document for your ACA filing. If you plan on submitting to the IRS electronically, you do not need to print a 1094-C; however you may print one if you would like to preview your electronic submission beforehand. If you plan on using the paper filing method for your year-end ACA filing you will need to print the 1094-C. Once selected, you will see the following window: Authoritative Transmittal? The 1 st question asks if this is the Authoritative Transmittal, and references question # 19 on the 1094-C. Answer Yes if you plan on filing the version you are now printing, otherwise answer no. Certifications of Eligibility? The 2 nd question concerns selections for your Certifications of Eligibility. The IRS has strict rules around what you should and should not select, and you should consult your accountant regarding which are right for you. The full guidelines can be accessed on from the link provided applied systems technology TECHNICAL DOCUMENT 10

11 on page 3 of this document. With that said, below are some guidelines. Note you may select more than one choice; you also can select none of the choices. Qualifying Offer Method In order to qualify for this you must have offered self-only minimal value insurance for less than 9.5% of the 2015 mainland federal poverty level (about $1,100 for the year). Very few staffing companies will be eligible. There are additional regulations regarding eligibility to select this setting, and you should consult with your accountant before checking this. Qual Offer Method Trans Relief Please consult your accountant to see if you are eligible for this transition relief. Section 4980H Transition Relief For 2017 calendar year, the transition relief is applicable only if an ALE Member offers coverage under a health plan with a plan year beginning on a date other than January 1. Consult with your accountant if you qualify for all the terms of this special Transition Relief. 98% Offer Method This option can be checked if you offered affordable insurance offering minimal essential coverage and minimal value to at least 98% of your full time employees.. Persona will first analyze your data to see if this choice is even an option for you. If you qualify by way of your ACA data, you then get to select Y/N if you wish to file with this Transition Relief. Again, consult your accountant before checking this field. Correction? Only answer Yes to this question if you have already submitted your 1094-C to the IRS, and are reprinting a new 1094-C to submit another corrected version to the IRS. Once the above questions are answered, you will come to your printer settings. Printer Choices The printout to the landscaped 1094-C form requires complicated initialization strings sent to your printer. Depending on your printer type you may find some Persona print definitions fit the form better than others. When printing, choose the Output Options Menu to select an Alternate Printer. Your Persona system has been setup with 3 new printer records: ACA1, ACA2, and ACA3. Feel free to try each one to find the one that most closely lines with the 1094-C form. applied systems technology TECHNICAL DOCUMENT 11

12 Should ACA1, ACA2, or ACA3 not appear in your printer listings, or the forms not line up using any of the definitions please contact AST Support. Paper Output of your 1094-C The 1094-C is a 2 or 3 page form (depending on if you have multiple EIN s in your ACA Control Group. You will need to load the pages for these forms in your printer as you wish them to output from the printer (i.e. page 1, then 2, then 3). Override of Field Column A for Non-Calendar Relief If your agency qualified for non-calendar relief as set in your ACA control record(s) PR-07-20, you may be able to override the system calculations for fields column a), based on certain somewhat complicated regulations. You will be given a chance to do so prior to the printing of the form. You should consult your accountant before changing any of the Y/N for any month of field column a). applied systems technology TECHNICAL DOCUMENT 12

13 Step 10 Create Electronic ACA Submittal Select the type of output: E for electronic file. Refer to step 9 for information regarding the prompts. You must utilize Solv s (formerly known as IBF) services to submit the electronic files to the IRS for you. You can reach a Solv representative at The rules and regulations put forth by the IRS have proven to be too risky for AST/Avionte to take this on. There will be two files in your year-end company folder. Both files should be sent to Solv. The file names are: c_request yyyymmdd XML (XML type file) 2. Manifest_1094c_request..XML (XML type file) Note: These are the only two files needed by Solv regardless of whether they are printing 1095c s for you or just submitting the files electronically for you. applied systems technology TECHNICAL DOCUMENT 13

14 Appendix A FAQ s 1) What should I do to prepare for ACA year-end filings? Be sure to have all your insurance offer information entered into your year-end company. This includes an effective date on every insurance offer, whether or not the insurance was accepted. 2) How do I order 1095-C forms/1094-c form? Or How do I outsource the printing/mailing of the 1095-C s? You can order the 1095-C forms/1094-c form from AST Forms & Supplies, If you use another forms company, be SURE to choose Landscaped and not Portrait. To outsource the printing/mailing of these forms, contact Jamie McCormick at Solv; JMcCormick@thesolvgroup.com. 3) Will everyone paid in 2017 receive a Form 1095-C? No. There are two groups of employees who will receive a form 1095-C. The first is any employee who worked FT for at least a part of the year, as seen in their ACA measurement records (NOT check history). The second group are those people not full time, but who enrolled in a selfinsured plan you offered. 4) What are the deadlines for ACA? The employees need to get the 1095-C s by January 31, The IRS needs your filing either by February 28, 2018 (paper filing), or April 2, 2018 (e-filing by Solv). 5) What Needs to be Sent to the IRS? The IRS wants copies of all the 1095-C s that you gave out to employees, as well as a summary 1094-C. 6) I Pay Staff out of a Separate Program, but want to file ACA for Temps and Staff out of Persona. What do I do? You will need to manually create ACA measurement records out of your year-end company for these folks, AND you will need to manually enter the 1095-C records. Also you will need to set a termination date on the employee record if the employee did not work all year. Finally you will need to record any insurance offers you made to such employees. Feel free to contact AST support for this. applied systems technology TECHNICAL DOCUMENT 14

15 Appendix A IRS Codes applied systems technology TECHNICAL DOCUMENT 15

16 Appendix B Logic for who receives a 1095-C, and how IRS codes are determined for Box and Section III. Step 1 Creating a Subset of Employees who get a 1095-C Only certain employees receive 1095-C s. These employees are those that were considered Full-Time at some point in the reporting year (via their ACA measurement records), OR if not, they enrolled in a selfinsured plan at some point in the reporting year. 1) First, the system will run the ACA Weekly Utility as of the end of the reporting year (12/31) to be sure breaks-in-service are up to date. 2) Secondly, the system looks at ACA insurance records for any employee who Accepted/Enrolled in a Self-Insured MEC plan (MEC only or MEC+MV). These employees will receive a Form 1095-C. On the insurance offering, a. If the date accepted is zero or the coverage through date precedes the first of the current year, skip. b. If the coverage through date is zeroes and the effective date is in the previous year, obtain the insurance end month and day from the related ACA control record. If the insurance end date (using the previous year) is after the effective date, coverage ended in the previous year, so skip the record. c. If the effective date is future to reporting year, skip the record. d. If the record passes the previous tests and the insurance type is self-insured and the insurance MEC flagged is checked, write a 1095-C workfile record. 3) Lastly, look for any employee that had a Full-Time measurement record for at least a portion of the reporting year. Here look at ACA measurement records. a. If the employee has already been written from insurance processing, skip (although still write the FT flag in e) below if FT). b. If the next eval date is prior to the reporting year, skip. c. If the employee measurement record status is full-time, the record is the active (most recent) record, and the break in service is zeroes, write a 1095-C workfile record. d. If the break in service of the measurement record is not zeros, determine the rule of parity for the employee class. i. If using rule of parity and the break in service date is within the reporting year, write a 1095-C workfile record. ii. If not rule of parity, find the difference between the break-in-service date and the start of the year. If this is greater than 90 days, write a 1095-C workfile record. e. Note any employee that was FT for at least part of a month will be marked as such on the 1095-C build program. 4) If an employee had a last check date prior to the start or the reporting year, they should not get a 1095-C. applied systems technology TECHNICAL DOCUMENT 16

17 We are now dealing with the subset of employees that have a 1095-C workfile, and everything below deals with these employees only. Step 2 Fill in fields 1-13 (and Plan Start Month) 1) This information comes from Employee Record and XX record. 2) Plan Start Month looks at ACA Control records for the class of that employee to get this. Step 3 Fill in Lines 14 and 15 of Form 1095-C 1) Look through employee Insurance records to put in Field 14 month-by-month codes of 1A-1I (as defined in field 15 of the Employee Insurance Record). a. Logic will be the same as in Step 1 to determine coverage, with the exception that we will write box 14 values for both self-insured and fully-insured. The MEC flagged being checked requirement stays the same. b. Note an offer of coverage in field 14 is true ONLY if it would cover the whole month; partial offer should not show an offer and would show a 1H code. This is true for the date of hire month and the termination month (break-in-service month). i. Code 1H will prevail for months after the break in service as well, until another insurance offer was made in the reporting year. 1. Client will have option of having the insurance builds ignore BIS where the person worked again. ii. System will also check last check date or termination date, and coverage will not show offered past one of these. The system will use last check date up to 90 days from 12/31 (October 2 nd ) for this. Past October 2 nd the system will not check the last check date but will check the employee termination date (looking for dates 10/3-12/31 only). 2) There is a special consideration for code 1G. 1G is reserved for an employee who enrolled in self-insured MEC coverage for one or more months, AND was not a FT time employee for any month of the calendar year. a. Clients may not have handled code 1G properly throughout the year, so b. If the IRS coding for the insurance record was 1A-1F, AND the insurance accepted was self-insured (and MEC), AND the employee was not FT for any month of the calendar year (as set in the FT flag on the 1095-C build file, set in Step 1), Persona should override the IRS code in field 14. In such a case, 1G should be put in the all 12 months box and do not complete the monthly boxes. i. Note if 1G is setup as such, fields 15 and 16 are not to be filled in. c. The system will provide an error report where 1G was selected but the insurance was not self-insured, or the employee was FT. applied systems technology TECHNICAL DOCUMENT 17

18 3) If you have multiple offers during the reporting year, followed below logic. a. If the effective date is the same, use the plan first that is Minimal Value (if they are both MV unlikely use either one). If neither is Minimal Value but at least one is MEC, use that. b. If the effective dates are different, use the plans in succession. So for instance if one covers Feb-Dec and the other covers July-Dec, then the 1 st plan will cover Feb-June, the second July-Dec. 4) Once field 14 is established, now fill in field 15. Only if field 14 is code 1B-1E is field 15 filled out. Field 15 will come from the employee Insurance record, field 15. Step 4 Fill in Line 16 of Form 1095-C Logic is in order: 1) If the corresponding month box 14 is 1A-1F, and that insurance is accepted, the code should be 2C. This means the insurance coverage was for the whole month, and the employee was employed the whole month. a. Do not enter code 2C if box 14 is 1G in the all 12 months box. In such a case leave field 15 and 16 blank. 2) If the month is not already 2C, and the corresponding box 14 month is 1H, and the employee was not an employee for any part of the month (via the measurement records - Hire and BIS dates, or the Last Check Date/Termination Date), the code should be 2A. a. The logic will use the measurement data to determine working status. If the break-inservice date is within the month, do not use code 2A. 3) If the month is not already code 2C or 2A, and the corresponding box 14 month is 1A-1E (MV insurance offer), and the insurance was not accepted, and the safe harbor method for that insurance was W-2, enter code 2F. 4) If the month was not already 2C, 2A, or 2F, and for any part of a month the employee is on a Variable or Seasonal ACA Initial status, enter a code 2D. a. If there s a measurement record immediately following the Variable or Seasonal record (using next/last eval date to determine), and that new record is FT, that 1 st month of the new measurement should be code 2D, with two considerations: i. That month is not already 2C or 2A or 2F, AND ii. There is an insurance effective date within 31 days of the last eval date of the new FT measurement, and that insurance is both MEC and MV, and that insurance was accepted. iii. If that qualifying insurance offer was not accepted however enter 2F-2H according to the insurance setup safe harbor method. 5) If any part of a month has a Part-Time measurement, and that month is not already coded 2C or 2A or 2D or 2F-2H, it should be coded 2B. applied systems technology TECHNICAL DOCUMENT 18

19 6) If an employee is FT according to measurement, and the month is not 2C or 2A or 2D or 2B or 2F-2H already, should be coded under code 2B, or 2F-2H, or 2D, or with nothing. Logic is in order: a. For the above circumstance the code should be 2B for January only if the corresponding box 14 code is 1A-1E (if not coded already). b. For the above circumstance the code should be 2B if the employee was FT, had a breakin-service within the month (or last check date/termination date logic for Oct-Dec), the corresponding box 14 is 1H, but there was insurance effective for the month up to the break-in-service/last check date/termination date (if not coded already). i. Intent is the employee terminated/stopped work in month. So above question for non Rule of P and Rule of Parity of ending all checks vs. break-in-service date applies. c. For the above, if the ACA Hire date is in the month (not the 1 st ) and the measurement is FT, the code will be 2D (if not coded already). d. For the above circumstance, the code should be 2F-2H as defined in the insurance safe harbor if the corresponding box 14 month is 1A-1E and the insurance was not accepted (if not coded already) e. For the above circumstance, the code should be 2D for the three months after the hire date month (or if the hire date was the 1 st, three months starting with the hire date), but only if on the 1 st of the 4 th month after hire (or 1 st of the 3 rd if the hire date was the 1 st ) there was an insurance offer effective date that was MEC+MV. i. This will be true even if the system has to look into 2018 for effective dates. f. The code should be blank in all other cases that an employee is a FT employee. applied systems technology TECHNICAL DOCUMENT 19