ACA Period Records, Dependents, & Coverage Dates in Munis JANUARY 21, 2016

ACA Period Records, Dependents, & Coverage Dates in MunisJANUARY 21, 2016

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New Reporting Due Dates

QUESTIONS? [email protected]

Old Deadline

New Deadline

Deadline to Distribute Forms to Employees and Covered Individuals

Feb. 1, 2016

March 31, 2016

Deadline to File with the IRS (paper)

Feb. 29, 2016

May 31, 2016

Deadline to File with the IRS (electronic)

March 31, 2016

June 30, 2016

The IRS has extended the deadlines for ACA reporting/filing under IRS Notice 2016-4.• The delay allows DEI to provide the

most up to date information on dependents and potentially reduces the number of 1095 corrections your district would have to process.

• Wait to file electronically until closer to deadline. Can make corrections without filing corrected returns.

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Impact on Employees Due to these extensions, some individual taxpayers may not receive a Form 1095-B or Form 1095-C by the time they are ready to file their 2015 tax return. While the information on these forms may assist in preparing a return, they are not required. Like last year, taxpayers can prepare and file their returns using other information about their health insurance.

Individuals do not have to wait for their Form 1095-B or 1095-C in order to file per the IRS.


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Good News! Penalties will not be imposed if you make a good faith effort to comply with the reporting requirements. ◦ But only for incorrect or incomplete information reported on the return or

statement. ◦ No relief available if good faith effort is not made or there is no timely filing of

an information return or statement. Bottom line: ◦ Make a good faith effort. ◦ File on time. ◦ If you make mistakes, fix them as soon as possible.


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Filing Electronically with the IRS Electronic filing will be through the IRS Affordable Care Act Information Returns (AIR) Program.

If you are filing yourself (i.e., not using a vendor), you must take steps before you can file electronically with the IRS.

Step 1: Identify your Responsible Official(s) and Contacts. Two are required.◦ Must have at least one Responsible Official. ◦ The Responsible Official(s) is responsible for & has authority over the e-filing of ACA returns. ◦ The Responsible Official is also the first point of contact with the IRS & has authority to sign the

application for the Transmitter Control Code (TCC). ◦ Contacts should be available for inquiries from the IRS on a daily basis. Must have a minimum of two.


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Filing Electronically with the IRS Step 2: Login or register with IRS e-Services. Step 3: Complete ACA Application for TCC.

◦ For more information, see IRS tutorial available at: https://www.irs.gov/PUP/for_taxpros/software_developers/information_returns/aca_app_tutorial_online.pdf

Step 4: Receive TCC (either via mail or online). Step 5: File forms.


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Who Should Receive a 1095-C Form?

All Applicable Large Employers (ALEs) must file Form 1095-C for each employee who was FT for any month of the calendar year.

ALEs (generally those who employed an average of at least 50 FTE’s throughout the year) sponsoring a self-insured plan (KEHP is considered self-insured) must complete Parts I, II & III for any employee (including Board Members) who enrolls in the plan for any month of the calendar year, whether the employee is FT or not.

For purposes of reporting on Forms 1094-C and 1095-C, an employee in a Limited Non-Assessment Period is not considered a full-time employee during that period (employees would not start insurance until at least 1/1/2016).


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Who Should Receive a 1095-B Form?

The only districts who will need to use the 1095-B form would be self-insured clients who are not also Applicable Large Employers (i.e. who have less than 50 FTE’s).

Most steps discussed in this presentation will apply, however the settings for the 1095-B generate function will differ from 1095-C settings.


QUESTIONS? [email protected] 9

Okay, but what do I do?

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Step 1 - Create and Maintain Standard and Initial Period Records

A. Setup ACA GroupsB. Complete ACA Group/BU CrosswalkC. Complete ACA Variable Pay Status CrosswalkD. Create Period DefinitionsE. Mass Add Initial ACA Period RecordsF. Generate Standard ACA Period Records with stability dates that encompass

2015. G. Generate Standard ACA Period Records with stability dates that encompass

2016.


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Step 1 - Create and Maintain Standard and Initial Period Records

Setup ACA Groups:


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ACA Group/BU Crosswalk


Districts may have created their own Group/BU or additional ACA groups that are not included in the example and will require additional crosswalks to be identified.

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Variable Pay Status Crosswalk


Districts may have created their own Personnel Status’ that are not included in the above example and will require additional crosswalks to be identified.

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Create Standard Period Definitions

The following ACA Standard Measurement/Waiting and Administrative dates are based on the “Affordable Care Act – Implementation Guide for Kentucky School Districts” which recommends a 12-month measurement period beginning October 3, 2013.

This Reporting Year Dates:◦ Measurement/Wait: Start: 10/3/13 End: 10/2/14◦ Administrative: Start: 10/3/14 End 12/31/14◦ Stability: Start: 1/1/15 End 12/31/15


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Standard Period Definitions


Create two Standard Period Definition records, one should be marked as Variable.

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Initial Period Definitions (new hires)


Create two Initial Period Definition records, one should be marked as Variable. Refer to the documentation.

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Initial ACA Period Records Records


Once Initial Period Definitions are setup, new employees will automatically have ACA Period Records created.

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Mass Adding of Initial ACA Period Records


Select the appropriate Date Type utilized by your district so that records are only generated for employees who were hired during the year.

If your district enters a new Hire Date any time an employee changes jobs, then you should select another Date Type from the drop down box.

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Generate ACA Standard Period Records


This steps assumes no records were generated at the end of last year for this year’s stability period.

If records were created in December 2014 you may skip this step.

Mark “Include Inactive Employees” in order to create records for those employees who are now inactive, however were employed and had insurance during the 2015 calendar year.

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Once the generate process is completed, each full time employee who was employed before the start of 2015 should have a Standard Measurement Period record with the below information.

Measurement/Wait: Start: 10/3/13 End: 10/2/14 Administrative: Start: 10/3/14 End 12/31/14 Stability: Start: 1/1/15 End 12/31/15


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Create standard records for calendar year 2016 to aide in next year’s 1095 reporting.

This is important to do now and not wait as it will simplify reporting the following year.

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Once the generate process is completed, each full time employee who was employed before the start of 2016 should have a Standard Measurement Period record with the below information.

Measurement/Wait: Start: 10/3/14 End: 10/2/15 Administrative: Start: 10/3/15 End 12/31/15 Stability: Start: 1/1/16 End 12/31/16

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ACA Standard & Initial Period Records

1. If you have a Full Time Employee with insurance in 2016 that has since left employment, add a Standard ACA Period Record for the employee for next year’s 1095 reporting.

2. All 2016 new hires need an Initial record. Once setup is complete records will automatically be added for them, however for any employee hired prior to setup being complete should have an initial record for next year’s reporting.


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Step 2 – Period Record Script The Period Record Script was created by KDE/Tyler to allow for a one-time adjustment of ACA records related to the startup of ACA period records. The Period Record Script performs the following tasks:

1. Remove Standard records for employees with a TERM date prior to 1/1/2015.

2. Remove the Standard record when both Initial and Standard records exist.

3. Set Coverage Offered flag on FT employees.


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Step 2 – Period Record Script The Period Records Script cannot be run by the district but must be requested by each district once the following steps have been performed:

1. Generated Standard Records

2. Generated Initial Records

3. Employees no longer covered under health insurance have a TERM date on the Employee Master.


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Step 2 – Period Record Script To run the script for your district please send an email with the following information:◦ Email Address: [email protected]◦ Subject: “Period Record Script - Androscoggin County”◦ Body: Please run the script for Androscoggin County’s ENV (ENV

must be Live, Train or Test)

Your district is responsible for ensuring the remaining records and updates are correct and comply with Federal ACA reporting requirements. Any additional changes to these or other records are the responsibility of the district.


mailto:[email protected]

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Step 3 – Mark/Unmark “Coverage Offered” flag on ACA period recordsAfter the script is run that flags all full time employees as being offered insurance, additional review is still necessary. a. After the script is run, users will need to manually indicate if coverage was offered to

any employee that was not full time by marking the “Coverage Offered” flag on the ACA Period Record.

b. After the script is run, users will need to manually unmark the “Coverage Offered” flag on the ACA Period Record if any full time employee was not offered insurance.


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Step 4 – Make Adjustments to ACA Period Records


• Admin and Stability Dates on the ACA Period Record determine what codes are generated on the employee 1095-C. The best way to ensure proper codes are used in to make adjustments to the period record rather than the individual’s 1095 form.

• Substitute or PT employees who switched to Full Time during the calendar year and were therefore were offered insurance, will require two period records.

• The employee should already have a Standard Period record that must be edited and additional Initial Period record is required.

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The employee was hired before 1/1/15 but was not eligible for insurance and no offer of coverage is marked.

Period Group Type: Standard Record

Full Time: Undetermined

Variable Marked

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The variable status employee becomes a full time employee an additional ACA Period Record is required with the following items set:

Period Group Type: Initial

Full Time – Yes Coverage

Offered Flag Set Administrative

Period Dates entered

Stability Period Dates entered

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After the 1095 is generated the proper codes are reported.

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Employees that leave employment and return later in the year also require additional adjustments to the ACA period record in order for the 1095-C to process correctly. This Full Time status employee terminated employment on 3/31/15.


Period Group Type: Standard

Full Time: Yes Stability

Period: Ends at Termination

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Period Group Type: Initial

Full Time: Yes Admin Period:

Hire Date to end of second month

Stability Period: HI Coverage Dates

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After the 1095 is generated the proper codes are reported.

Note: All 1095-C may be manually edited.

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Step 5 – Import Health Insurance Dependents


• DEI is creating a file of dependent coverage dates that is expected approximately February 1st.

• Will contain records for dependents of members who have health coverage.

• Cross references where both members work for a school district: o The dependent File will have a record for each covered dependent, which

includes children and the spouse (cross reference secondary). Note, a cross reference secondary spouse will be reported as a dependent

on the primary plan holder and will also have their own 1095C form indicating coverage.

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Step5 – Import Health Insurance Dependents


Select Find and search on all records.o Determine if your district has any existing dependent records. o Any existing records will not interfere with the import however if coverage

dates are included on the existing records it could cause issues with 1095 reporting.

Download the Dependent File from the saved report directory using the File Transfer program.

o 20xxACADEP###-0001.txt where xx is the year and ### is the district’s KHRIS employer number.

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Employee Dependent Program:

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1. Enter a comma (,) for the Delimiter.

2. Update Option, select “Always Add As New Dependents” from the drop down menu when importing dependents for the first time.

3. Continue with Output-Post process.

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Review Dependent Records - CRUCIAL

Select Find and search for any dependent with a SSN of 999-99-9999 by entering 999-99-9999 in the SSN field as seen in the following screen shot.


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Reasonable Efforts to Obtain SSN


The IRS requires that all dependents have a valid SSN number reported and if not available the Date of Birth should be supplied in its place.• Print a report showing all the dependents who do not have a valid social security

number. • The IRS requires that effort be made by the employer to solicit the employee to

request the SSN. • The SSN should be updated in KHRIS and within the Employee Dependent record in

Munis.

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So What is a Reasonable Effort? The rules state that the reasonable efforts mean asking for SSNs up to three times before any annual filing.

Open Enrollment can count as the first request as long as there is a field or place to provide the SSN/TIN.

The other two attempts for obtaining SSNs are generally required by December 31 of that same year and December 31 of the following year.


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So What is a Reasonable Effort?If enrollment counts toward the first attempt for obtaining SSN/TIN, then the second and third outreach are required within specified time frames.

1. Enrollment that takes place before December, must be followed by a second solicitation for SSNs/TINs by December 31 of that same calendar year.

2. If enrollment takes place in December, the second attempt to obtain the SSN/TIN must take place by the following January 31.

3. The third and final attempt to obtain SSN/TIN must take place by December 31 of the following year.

If all three attempts are made, and SSNs/TINs are still not available, employers sponsoring self-insured plans and insurers must use date of birth to help the IRS confirm identity.


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Step 5 – Import Employee Coverage Dates (Participant File)

What is included on the participant file? The participant file will contain records for members who have health

coverage and for those who have the Waiver HRA plan only. Cross References where both members work for a school district:

o Participant File will have one record for each employee.


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Step 6 – Import Employee Coverage Dates (Participant File) Cross Reference where only one member works for a school

district: o If district employee is primary plan holder –

Participant file will only contain one record, for the district employee.o If district employee is secondary plan holder –

Participant file will only contain one record, for the district employee.


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Step 6 – Import Employee Coverage Dates (Participant File) No records will be listed for members with:

o Waiver NO HRA o Waiver D&V HRA o Forced Waiver o “NonPaymt force waive” plans


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Importing Coverage Dates


How will it work?• DEI is creating a file of employee coverage dates that is expected

approximately February 1st.• KDE/Tyler will take the file, break it into individual Excel files (.xlsx)

and place it to your Spool folder of your Live environment.• Districts will download the file to a workstation for use during import.• Districts will use the Import button in the ACA Period Records program

to import the coverage dates.

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Importing Coverage Dates1. Select the

Import button

2. Click the radio button for “Import Employee Coverage Dates”


QUESTIONS? [email protected] 48

1095-C GenerationSTAY TUNED! MORE INFO COMING SOON!

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ACA Setup Questions????? Please send questions to [email protected].

This email box is monitored by the Munis team and your emails will be answered more quickly than emails sent directly to individuals.


mailto:[email protected]

Documents

ACA Period Records, Dependents, & Coverage Dates in Munis JANUARY 21, 2016