2015 16th annual pabug conference affordable care act: requirements, tracking and reporting don...

2015 16th Annual PABUG Conference

Affordable Care Act: Requirements, Tracking

and Reporting

Don Lerew (Messiah College)Michelle Spencer (Dickinson College)


General Announcements:• Please turn off all cell phones/pagers• If you must leave the session early,

please do so as discreetly as possible • Please avoid side conversations

during the session• Questions will be answered …..

Thank you for your cooperation


To receive CPE credits for this session (if eligible), complete the CPE Attendance Form on the PABUG Annual Conference website

http://pabug.org/pennsylvania-banner-users-group-annual-conference/cpe-credits/

or via the PABUG conference app.

For additional questions please contact

Kim Fremont CPE - Coordinator http://pabug.org/contact-us/

CPE Credits - We’ve gone electronic!



http://pabug.org/contact-us/


Institution Facts – DICKINSON COLLEGE

• Dickinson is self-funded with approximately 840 full-time employees; over 700 of those are enrolled in medical insurance

• We are planning on running 1095’s from Banner (not outsourcing)

• Dickinson already tracks dependents on coverage in PDABCOV

• Must provide forms for those on COBRA coverage and retirees/terminated employees with an active VEBA Emeriti account


Institution Facts – MESSIAH COLLEGE

• Messiah employees 625 full-time employees; 545 (87%) enrolled in medical insurance

• Messiah is NOT self-insured for medical insurance

• We are currently finalizing review to consider outsourcing 1095 process for 2016


Affordable Care Act

Background, Regulations and Reporting


ACA Regulations -- Background

• ACA individual reporting requirements– Started in 2014– “Individual play-or-pay” provision

• ACA employer requirements– Started in 2015– For “applicable large employers” (ALE)– “Employer play-or-pay” provision


ACA Regulations – Regulations

• §4980H– Applicable Large Employer (ALE) responsible to

pay Employer Shared Responsibility (ESR) payment if employer fails to offer minimum essential health insurance coverage OR the coverage is either unaffordable or does not provide minimum essential value

• §4980H(c)(4) Full-time Employee– An employee who is employed, on average, at

least 30 hours per week


ACA Regulations – Defining Periods

• Measurement Period (M.P.)– Period of 3-12 consecutive months over which

employee service hours are averaged to determine if the employee is full time

– Initial Measurement Period (I.M.P.)• For new variable-hour and seasonal employees• Start date varies based on employee’s hire date

– Standard Measurement Period (S.M.P.)• Employer-designated period that has fixed dates and

applies to an entire group of employees


ACA Regulations – Defining Periods

• Administrative Period (A.P.)– Optional period that allows time to notify and enroll eligible

employees for coverage– Begins at the end of the M.P. and may last up to 90 calendar

days• Stability Period (S.P.)

– Immediately after A.P. or M.P.– Employee is treated as full-time or non-full-time according to

findings during measurement period– Minimum six consecutive months; no shorter than M.P. for full-

time employees; no longer than M.P. for non-full-time employees


ACA Regulations – Full-Time Employee

• For calendar month, employee averages 30 hours of service per week or 130 hours of service per month

• Methods for Determining Full-Time Status– Monthly Measurement Period

• Employee has at least 130 hours of service in a month

– Look-back Measurement Period• Employee averages 30 hrs/wk or 130 hrs/mth over

established look-back measurement period


ACA Regulations – Includable Hours

• Each hour in which the employee is paid, or entitled to payment:– For performance of duties– For which no duties are performance

• Vacation, holiday, illness, incapacity (including disability), layoff, jury duty, military leave, leave of absence


ACA Regulations – Excludable Hours

• Worker’s Compensation• Volunteer employees for tax-exempt organization• Students performing work study through federal

work study program (or similar program)• Unpaid Internships• Non-US-Source Income• Temp Agency Employees• International Students (F, J, Q or M visas)


ACA Regulations – Hard-to-Classify

• Break periods of 4+ consecutive weeks must be excluded or credited

• Adjuncts with 26-week breaks can be considered a new hire upon return

• Seasonal employees with annual employment six months or less are NOT considered full-time employees

• Adjuncts must be credited with a minimum of 2.25 hours/week of service for each hour of teaching or classroom time (safe harbor)

• On-call employees credited for any hour of service on-call for which payment is made or due by the employer


ACA Regulations – Challenges

• Salaried employees in less-than-12-mth jobs• Employees with reduced summer hours• Graduate assistants if paid stipend• Summer athletic camp workers• Resident assistants• Assistant coaches• Others?


ACA Regulations – Employee Types

• Ongoing Employee– Has been employed by the employer for at least

one complete standard measurement period• New Employee

– Expected 30+ hours/week upon hire– Variable Hour cannot be determined to work 30

hrs/wk at start of initial measurement period• Transition New Ongoing Employee


ACA Regulations – Annual Reporting

• IRC Code §6056• ALE must file returns to IRS for each employee

who was a full-time employee during one or more months during the calendar year– Can be paper or electronic– Can be solely electronic only if employee consents


ACA Regulations – Annual Reporting

• Employees will receive:– 1095-C from employer– 1095-B from insurance provider, unless self-insured for

medical insurance• IRS will receive

– 1094-C from employer– 1094-B from insurance provider, unless self-insured for

medical insurance• COBRA reporting covered by insurance provider,

unless self-insured for medical insurance


ACA Regulations – Due Dates

• 1095-C forms– To each employee by January 31

• 1095-C forms & 1094-C transmittal– To IRS by February 28 (electronically, March 31)

• 1095-B & 1094-B– Dates follow due dates above when provided by

insurance provider


Affordable Care Act

Banner Processing


Banner Hours Tracking Setup Items

• PTRBCAT Benefit Categories– Is current structure sufficient?

• PTREARN Earnings Codes– Are the hours/units flags accurate?

• GTVSDAX – include or exclude ECLS and EARN codes• Run PHRAFCA process to look at hours by employee• Payroll

– Are the includable hours of service processed such that all appropriate hours are tracked?

• Retroactive Pay– How to handle late timesheets, etc.?


Banner Reporting Setup Items

• PTRBDCA – Complete fields under the US ACA section for the medical benefit codes that provide minimum essential coverage

• GTVSDAX – holds the crosswalk codes for PTRBDCA medical benefit codes and plan codes on PDADEDN records

• PTROCMU – specified by ECLS; must populate if running the Mass Update Process (PDPOCMU)

• PDPOCMU – if using to auto populate PDAHIOC records• PDAHIOC – individual employee ACA coverage records• PDRHIOC – Audit Report Process; used in reviewing PDAHIOC

records• PDABENE – dependent names, DOB and SSNs• PDABCOV – dependents on medical coverage


Benefits Mode – Indicating the Health Care Provider (PTRBDCA)


Benefits Mode – Crosswalk Validation (GTVSDAX)

• At Dickinson, we have over 200 medical plan options. GTVSDAX is limited to only a 2 digit Sequence so we narrowed the list down to only those codes that are being utilized.


Benefits Mode - Mass Update Rule Form (PTROCMU)

• Defaults are entered by Employee Class


Offer and Coverage Mass Update (PDPOCMU)

• Automates the creation of Health Insurance Offer and Coverage records (PDAHIOC);

• Run in Rule Mode (by ECLS) or Benefit Mode (actually looks at PTRBDCA and effective dated changes)

• Requires new entries in GTVSDAX for Benefit Mode


Offer and Coverage Mass Update (PDPOCMU)


Health Insurance Offer and Coverage (PDAHIOC)


Offer and Coverage Audit Report (PDRHIOC)

• Employees listed alphabetically by the employee class on PEAEMPL

• Includes an audit of ACA hours• Offer and coverage records for each employee• Messages identifying employees with no Offer

and Coverage record, incorrect code combinations, employees not enrolled


Other ACA Items to Consider

• Forms – Printing or providing electronic• Forms – blank or pre-printed• Forms – mailing with W-2 or separate• Electronic files for ACA submission – Ellucian is

testing• Register with IRS to be authorized to transmit

– Affordable Care Act Information Returns (AIR) Program


Open to the Floor

• Questions• Comments• Discussion


Contact Information

• Don Lerew– HRIS & Payroll Manager, Messiah College– [email protected]

• Michelle Spencer– HRIS Administrator, Dickinson College– [email protected]

mailto:[email protected]

mailto:[email protected]


Please take time to complete our Conference and Session

evaluations.

YOUR INPUT MATTERS!!!

2015 16th annual pabug conference affordable care act: requirements, tracking and reporting don...

Documents

pabug conference app

employerdesignated period

periodsadministrative

periodsmeasurement period

optional period

eligible employees

retireesterminated employees

timeinitial measurement