Affordable Care Act: Requirements, Tracking and Reporting Don Lerew (Messiah College) Michelle Spencer (Dickinson College)

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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

Background, Regulations and Reporting 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 DLerew@messiah.edu Michelle Spencer HRIS Administrator, Dickinson College spencer@dickinson.edu

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