ACA Company Build Out: Fully Insured ALE

Transcription

1 ACA Company Build Out: Fully Insured ALE Congratulations! You have a new client. Your team has been meeting with the bakery, Life of Pie, for quite some time and have finally closed the deal! This workbook will provide all of the information you need to get this group up and running for ACA Reporting. 1

2 Chapter 1 Purpose of IRS Filing Chapter Objectives: Identify the purpose of filing Identify if your company is an Applicable Large Employer and determine what forms need to be filed for your company Determine affordability and qualified offer for each employee for each month The IRS needs to determine whether or not each employee was offered health coverage and if it was affordable according to IRS regulations. If coverage was not offered or affordable, the employee then can purchase subsidized coverage on the public exchanges. Does my company need to file? Companies with over 50 full time employees are required to offer affordable coverage and file the necessary forms. Companies that need to file are considered Applicable Large Employers (ALEs). Calculating whether or not you have 50 employees is a bit more complicated. The following is a summary and you should consult your tax advisor to determine your eligibility, especially if you may qualify for the seasonal exception. 1. Determine the number of full-time employees expected to work over 130 for each month. 2. Calculate full-time equivalents for each month. Total the number of hours for employees who are not full-time. (Do not count more than 120 hours for any single employee.) Divide the total hours by Exclude Statutory Exclusions, those who are not common-law employees. 4. Add full-time employees + full-time equivalents statutory exclusions = total full-time employees for each month. 5. Add the 12 monthly numbers, and divide the sum by 12. If this number is less than 50, the employer is not an ALE. What forms are required to be filed? Forms Preparer Recipient Purpose 1095-C (Large Employers Fully- Insured or Self-Funded) Employer Employee Determines whether, for each month of the calendar year, an employee may claim the premium tax credit on their individual return C (Large Employers Fully- Insured or Self-Funded) Employer IRS Used to report to the IRS summary information for each employer and to 2

3 1094-B and 1095-B (Fully Insured) transmit Forms 1095-C to the IRS. Carrier IRS Used to report information to the IRS and to taxpayers about individuals who are covered by minimum essential coverage and therefore aren't liable for the individual shared responsibility payment B (Self-Funded) Employer Employee Small employers that aren't subject to the employer-shared responsibility provisions sponsoring self-funded group health plans will use Form 1095-B to report information about covered individuals B (Self-Funded) Employer IRS Used to report to the IRS summary information for each employer and to transmit Forms 1095-B to the IRS. Only eligible employees will be receiving a 1095-C form. When we say eligible, we mean employees that either have the ACA classification of Eligible or VH employees that were finalized as eligible (they worked 30 or more hours a week during their measurement period and are considered eligible). The end goal of determining eligibility is to identify the employees that need to receive a form and populate those forms with the proper codes. We have passed out copies of the 1095 forms populated with dummy data and the definitions of the Line 14 codes. We need to know eligibility of employees and plans to make these calculations in the system. Exercise 1.1: Determining what forms your company will be receiving To determine the forms that need to filed for this company, determine how many Full Time Employees, including Full Time Equivalents, work for the employer. More than 50 Fully Time Employees work at Life of Pie. Because the employer is an ALE, the 1094-C will be produced as the employer form, and employees will receive the 1095-C. 3

4 Chapter 2 Adding a Company Chapter Objectives: Identify Company information required to strategically use Employee Navigator for ACA reporting purposes Create a Company from your Agency HOME page When adding a group to Employee Navigator, you will want to gather as much information as possible from the group up-front to save you time in the long run. Gathering information such as Class Structure and Benefits offered which also includes the company contribution structures, and tracked Employee Demographic data will simplify the build out process Exercise 2.1: Add a Company To Add a Company, from the Agency level: Go to HOME > add a company Company Name Unique Identifier State Platform SIC Code: Agency User Access Life of Pie [Your Name] LifeofPie Maryland Enrollment Confectionary Select your name only TIP: Now that you have created the shell of your company, you will have landed on the GUIDE tab. Remember this page for later. You can always come back here to read an overview or support article of a function or use the Take Me There button to get you where you need to go. Chapter 3 Company Settings Chapter Objectives: Build a Class Structure to align with a Company s organizational benefit structure Describe the Pay Frequency hierarchy for Class Structures Create HR users with defined permissions Customize Employee Profile fields Profile The company Profile stores basic company demographic and industry information. To access and complete the company profile: 4

5 Go to SETTINGS > COMPANY > Profile Class Structure The system is built upon a rules engine which uses class structure as the foundation for all rules. You will be able to use the rules engine to build benefit eligibility rules, varied benefit or contribution structures, assign onboarding tasks and even determine which employees can view specific documents. Once you have a good understanding of this feature, you will be able to review each new group as a whole to determine how the class structure should be configured instead of using a piecemeal approach and having to back track later. For more information on this important foundation of the system, see the article on Defining Class Structure. Should I use "class" to separate the Full-time eligible from the Part-Time/Variable Hour employees? No! When using "Enforce Variable Hour Tracking" the system doesn't need to have both the company "class" and the ACA classification set up to differentiate the employees. With proper plan design, the variable hour employees will be in an eligible grouping under the medical plans; however, the employees who have an ACA classification of Variable Hour will not be marked as eligible for the medical plans until they pass their measurement period. You should not need to do a "class change" or an ACA classification change when a Variable Hour employee works enough hours to be considered eligible during their measurement period for purposes of making the employee eligible for the medical plans. Eligible: An employee who works more than 30 hours per week, and needs to be offered health insurance coverage. Ineligible: An employee who consistently works less than 30 hours per week, and will not have their hours increased. This employee will not be offered health insurance coverage. Variable Hour: An employee whose hours may vary, so that it is unknown if they will work 30 hours a week. A classification of Variable Hour will trigger the system to use the look-back measurement method to determine if based on the number of hour worked during the measurement period, the employee averaged 130 hours a month, and needs to be offered health insurance coverage. When determining an employee s classification, used the company s definition of full-time hours instead of 30; however doing so will require hours to be imported for all employees in order for the system to continue using the 30 hour ACA full-time definition to derive codes and determine who needs to have a 1095 filed. Exercise 3.1: Adding Class Structure At Life of Pie, there are three classes of employees. The table below has this information populated. The purposes of Classes is to vary health plan eligibility, waiting periods, and contributions by groups of employees such as departments, divisions, office locations, etc. These values will be used to generate the necessary codes for the 1095-C. For example, if full-time employees in Division 1 are eligible on their date of hire and employees in Division 2 are eligible on the 1 st of the month, following 5

6 60 days, you will need to create classes. If you do not need classes, use the general All employees class. Generally, classes should be created if: Employees have different eligibility requirements Per pay period contributions differ by class Let s do this now. Go to SETTINGS > COMPANY > Class Structure. You will see the default Class is already set up for you. Since Classes are required for all employees, the system is prepopulated with the default Class, but this can be changed by simply clicking the Edit link. To add additional Classes, click on Add a class +. The Class structure for your group is as follows: Class Name Partners Associates Staff Pay Frequency Monthly (12 periods) Bi-Weekly (26 Periods) Bi-weekly (26 Periods) HR Users Adding HR Users to the system allows HR to have administrative rights in the system and take on some of your workload. You can set permissions and access controls for HR Users if needed. This is a nice way to prevent them from messing up your hard work versus telling them Don t touch the plans! To add an HR User: Go to SETTINGS > COMPANY > HR Users > Add a user + Depending upon whether or not the HR user is also an employee, this process can get a bit tricky. Make sure to read the HR Users and HR Permissions article for detailed instructions on this process. HR Users will not be able to use the ACA tool if Mask SSN and/or Mask Salary are selected under Permissions. HRIS Field Tracking The HRIS Field Tracking tool allows you to customize the Employee Profile fields and indicate which fields are being tracked for changes, which fields are visible to HR, and which fields are required to be completed by HR for every employee. For more information on configuring these settings, see the article on HRIS Field Tracking / Employee and Dependent Profile Fields. You will want to have ACA Classification set as HR Required on under ACA/ Statutory Classification. 6

7 Exercise 3.3: Setting your HRIS tracked fields You are almost finished with your basic group setup. Let s set up the group so that the Division will be required for all employees to make sure it doesn t get skipped. Go to SETTINGS > COMPANY > HRIS Field Tracking > ACA/Statutory Classification >ACA Classification > check off HR Required > Save Chapter 4 Importing Chapter Objectives: Describe the 5 steps involved in every import process Identify best practices for importing data Import an Employee and Dependent census for a company Employee Navigator s import engine provides you with a tool to import Employee and Dependent demographic information, current enrollment records, demographic changes, beneficiaries, and manager assignments. This tool is very powerful and can overwrite good information if you are not careful. It is important to make sure that you understand the process and what the outcome of your import will be as imports are not able to be undone. Import templates can be downloaded from the system to simplify the task of gathering the necessary data and formatting it appropriately. To download import templates: Go to HOME > HELPFUL TOOLS & INFORMATION > Import Employees & Enrollment > Download templates > select the appropriate template If you are using us for full Ben Admin you will use the Employee or the Employee/Dependent Census to get information into the system. These censuses have required fields for our full ben admin system, not just ACA. If you are only using us for ACA Reporting purposes you will want to use the Employee/Dependent ACA Updates census. This census only has the required fields for ACA Reporting. For information on selecting the correct import template for your data, see the Import Templates article. During the Import process, the system will lead you through the following 5 steps: 1. Upload add a file by browsing your PC or use the drag and drop option 2. Options Indicate what type of data is being imported 3. Map Map your column data to the correct system fields 4. Audit Audit any data from your import spreadsheet that does not match the system options 7

8 5. Commit Presents a final overview of the data you are importing and commits the data to the queue for processing To start a new import: Go to HOME > HELPFUL TOOLS & INFORMATION > Import Employees & Enrollment > Start a new import+ What is the ACA Classification field that needs to be imported? The ACA Classifications that are going to be imported for your employees are Eligible, Ineligible, or Variable Hour. How does the system use the ACA Classification? When determining the eligibility for health insurance, the system uses this value to look at the ACA measurement and stability periods (not ACA FT eligible) OR the default eligibility for each plan (ACA FT eligible). For example, employees not ACA eligible will need to be measured using the look-back measurement method to determine if they are eligible for coverage. This result in ACA eligibility may be a 1 year measurement period for variable hour employees vs. 1 month waiting period for full-time eligible employees. Needless to say, the system will not work if the ACA classification is empty. It is also important to note that only employees who have an hourly compensation type are being measured. It is assumed that employees with an annual salary have set hours, and therefore will not need to be measured. Which employees should I import? Employees who were employed at any time during 2016 should be imported. If you are well versed with ACA regulations, you can adjust who you import, but we advise just importing all of your employees if you will be importing hours. If you have not imported all of your employees, and try to import their hours, the file will error out because the hours will have no record to which to attach. You will need to import employees on COBRA, retirees, and dependents if you are a small, self-funded employer or if you are an ALE with a self-funded plan. For small employers, the 1095-B is reporting information about each covered individual. The B Series forms require the enrollment information for all covered individuals to be reported. Therefore, it is necessary to have COBRA, retirees, and dependent information. For an ALE, the enrollment information for anyone enrolled in the self-funded plan will be reported on Part III of the 1095-C. Advanced classifications In some instances, your company may have additional classifications which can be imported into the system for tracking purposes. For example, partners in a partnership are not considered employees and do not need a 1095-C generated. Another applicable use of advanced classifications could be applied in determining if you may qualify for an exception as an ALE, if the number of employees over 50 are seasonal and meet specific requirements. If you would like to import the following fields, just add columns to the spreadsheet and import them into the system. These advanced options are: Statutory class Seasonal employee Collectively Bargained 8

9 Retired Exercise 4.1: Importing your census The HR department at Life of Pie has provided you with the Employee and Dependent census included below*. You will need to download this workbook to your computer: See Supplemental Documents for ACA Training Workbooks. Follow the steps below to upload the Employee and Dependent Census: Go to HOME > HELPFUL TOOLS & INFORMATION > Import Employees & Enrollment > Start a new import+ Because you are reporting for a fully insured ALE, you will be reporting only on employees in the company. However, this group is using Employee Navigator for full benefit administration so you are also imported dependents into the system on this file. These dependents will not be reported on. 1. Upload: Click to add a file > Browse to select the file from your computer. 2. Options: a. Overwrite the File Name to Life of Pie ACA EE and Dep Census b. What are you importing? Select Employee Census c. Are dependents included in the file? Check Yes d. Save 3. Map: a. Scroll across to make sure nothing that you want to import into the system is set to skip 4. Audit: a. Class i. Map Assoc Associates b. ACA Classification i. Map Eligible Eligible (Regularly works more than 30 hours a week) ii. Map Ineligible Ineligible (Regularly works less than 30 hours a week) c. Save 5. Commit: Review the number of employee and dependent records, then click Commit. Note: Depending upon the size of your import, this process could take some time to complete. You will receive an notifying you when this import has been fully processed. All of the group s employees and dependents are now uploaded in the system. Chapter 5 Medical Plan Builds Chapter Objectives: Define why Medical Plans are important to the ACA reporting process 9

10 Create a base medical model plan using the new Add Plan In this chapter you will learn how to build a medical in Employee Navigator. Your medical plans need to be created in the system so the IRS codes can derive data. For example, the system uses the eligibility waiting periods completed so an eligibility of 1 st of the month following 30 days of employment can create a code for the partial month the employee was in a Limited Non-Assessment Period or Measurement Period and another code for the following month in which they were eligible. These codes will be added on Line 14 of the 1095-C. Go to BENEFITS > BASIC > Add Plan> select from the following options: Add a new plan: Select a plan model and build the plan from scratch Copy a plan from this company: Copy a selected plan from the current company and only make the necessary changes. Copy a plan from another company: Copy a selected plan form another company under your Agency and only make the necessary changes. Add a plan from My Marketplace: Copy a selected plan from a Template Company created at the Agency level. This option will only be visible if a template company was previously created. When using the Add a New Plan option, continue as follows: Select Plan model > Select Carrier > Enter New Plan Name > Save Included below are details on the primary building blocks of Basic Plans. Keep in mind, Policy Information and Eligibility Rules are consistent through all plan models. You will notice that on each plan model there are required fields which must be completed to turn on a plan for enrollment. There are also optional fields which can be built out to provide additional information for employees and utilize advanced tools and functionality in the system. POLICY INFO Policy Info Plan Name Name this something unique from year to year so that you don t get confused as to which plan you are reviewing (ex: 2016 HMO Gold Plan) Carrier Plan Type Start and End Dates Policy # ELIGIBILITY & ENROLLMENT Eligibility Rules Eligibility: o Everyone all employees are eligible for the plan o Rules Based (Class, Division, Is Exempt, etc.) use one of these options to indicate which group(s) of employees are eligible for the plan. 10

11 Coverage Waiting Period o Can be based on Everyone or rules based. o Enter numeric value and select from Days, Months, Quarters Coverage Begins/Entry Date (After Waiting Period) o Can be based on Everyone or rules based o Select from the following options: Hire Date 1 st of Month after Hire Date 1 st of the Month Coinciding with or after Hire Date 15 th of the Month after Hire Date 15 th of the Month Coinciding with or after Hire Date Termination Date o Can be based on Everyone or rules based o Select from the following options: End of Month of Termination Employment Termination 1 st of the Month after Employment Termination TIP: Plan Termination rules must be assigned to ALL groups of employees regardless of the plan eligibility. They can be rules based but each employee must have a termination rule. Whenever possible, use the Everyone rule. Why? you ask. Think about this. An employee is in the Executive class and is eligible for the STD Buy-up plan. The employee then has a class change and is now in the Staff class. The employee is no longer eligible for the plan, but if there are no termination rules for that class, the system is unable to terminate coverage for the employee. Therefore, all employees must have a termination rule assigned for every plan. COSTS Rates o Monthly Carrier Rates Composite Rates One set carrier rate for each coverage tier. Does not consider Employee or Dependent demographics. Banded Rates Carrier rates are Banded and based on the Employee s Age, Gender, Tobacco Use status, or any combination of the three. Does not consider dependent demographics. ACA Rates allows for configuration of rates based on individual age, geographic rating area, and tobacco usage. Rates are calculated for each individual enrolled (employees and dependents). Contributions Medical contributions can be set up to apply to all employees or use the rules engine to define different contributions for employees based upon Class, Department, Tobacco use, Wellness participation and other settings. 11

12 When adding plan contributions, you must always enter a monthly amount. Select from the following contribution configuration options for each of the applicable coverage tiers: The Employee Cost $: Amount the employee pays per month The Company Cost $: Amount the company pays per month The Company Contribution %: Percentage of the total cost the employer pays. Useful when rates are age banded. Additional Employee Cost $: (Dependent only option) Amount of $ the employee pays in addition to the cost of the Employee Only coverage in the same plan. Additional Company Cost $: (Dependent only option) Amount of $ the employer pays in addition to the cost of the Employee Only coverage in the same plan. Additional Company Contribution %: (Dependent only option) Additional % the employer pays in addition to the cost of the Employee Only coverage in the same plan. Exercise 5.1 Building a Medical Plan Life of Pie offers two medical plans for their employees to choose from. The firm covers 75% of the cost of the Base Plan for their employees and the employee is responsible for the remainder of the employee cost, any dependent costs, and the difference in cost when the buy-up plan is selected. This might seem a bit complicated, but rest assured, we this configuration covered. Follow the steps below to build the Medical Plans for this group. Go to BENEFITS > BASIC > Add Plan > Add a new plan + > under the Basic models, select Medical. Carrier = Anthem Blue Cross Blue Shield New Plan Name = 2016 Base Medical Plan 1. Build Your Base Medical Plan Be sure to hit Save after each section. POLICY INFO Policy Info ELIGIBILITY & ENROLLMENT Eligibility Rules Field Entry Plan Name 2015 Base Medical Plan Carrier Anthem Blue Cross Blue Shield Plan Type HMO Start Date 09/01/2015 End Date Will populate to 08/31/2016 but can be modified SAVE Eligibility Coverage Waiting Period Everyone Based on CLASS > Partners > 0 Days 12

13 Eligibility Options Enrollment Options COSTS Rates Coverage Begins/Entry Date Termination Date Over age dependent drop rule Enable auto drop of over age dependents Based on Class > Assoc & Staff > 30 Days Based on CLASS > Partners > Hire Date Based on CLASS > Assoc & Staff > 1 st of the month coinciding with or after Hire Date Everyone > End of Month of Termination SAVE End of month Check this box SAVE Dependent age not 26 eligible Student Age not eligible 26 Primary Care Physician Required PCP Link SAVE Is this plan based on Composite composite, ACA, or banded rates? Max children + children 26 rate SAVE Composite Plan is not self-funded: Do not check the box Monthly Rate Employee $150 Contributions Employee + Spouse $200 Employee + Child $200 Employee + Children $250 Employee + Family $350 SAVE Contribution Groups: All Employees Employee Company Contribution % = 75% Employee + Spouse Additional Company Contribution % = 0% Employee + Child Additional Company Contribution % = 0% Employee + Child(ren) Additional Company Contribution % = 0% Employee + Family Additional Company Contribution % = 0% 13

14 Policy Info SAVE Enroll Status > On 2. Build your Buy-Up Medical Plan POLICY INFORMATION Policy Info Eligibility Rules Eligibility Options Enrollment Options COSTS Rates Field Entry Plan Name 2015 Buy-Up Medical Plan Carrier Anthem Blue Cross Blue Shield Plan Type HMO Start Date 09/01/2015 End Date Will populate to 08/31/2016 but can be modified SAVE Eligibility Coverage Waiting Period Coverage Begins/Entry Date Termination Date Over age dependent drop rule Enable auto drop of over age dependents Everyone Based on CLASS > Partners > 0 Days Based on Class > Assoc & Staff > 30 Days Based on CLASS > Partners > Hire Date Based on CLASS > Assoc & Staff > 1 st of the month coinciding with or after Hire Date Everyone > End of Month of Termination SAVE End of month Check this box SAVE Dependent age not eligible 26 Student age not eligible 26 Primary Care Physician Required PCP Link SAVE Is this plan based on Composite composite, ACA, or banded rates? Max children + children rate 26 SAVE 14

15 Composite Monthly Rate Contributions Policy Info Plan is not self-funded: Do not check the box Employee $250 Employee + Spouse $350 Employee + Child $350 Employee + Children $450 Employee + Family $550 SAVE Contribution Groups Grouped By > Everyone > Add + Use Plan Based Contributions Select 2016 Basic Medical Plan SAVE Enroll Status > On **If you have mid-calendar year plans, you need to build both plans for ACA Reporting. Because you have 9/1 plans you will need to build your 9/1/2016 plan so that we can account for all of 2016 for reporting purposes. To add this plan, select renew plan on both the 2015 Base Medical Plan and 2015 Buy-Up Medical Plan. Rename the renew plans 2016 Base Medical Plan and 2016 Buy-Medical Plan.** Do I need to add all medical plans, or just the low cost plan? If using the system for ACA reporting only, you only need to add the low-cost plan. Enrollment will be collected based on enrollment in a medical plan, not specifically the low-cost plan. The system will not be an accurate source for reporting on coverage or costs, but will be able to derive the correct 1095 codes. If using the system for full benefit administration, all plans need to be added. Chapter 6 Missing ACA Information Chapter Objectives: Identify where to find and correct missing ACA information We have created 2 tools to identify any employees who are missing the necessary data required to generate the 1095 s or You can either use these tools or import the missing data with a spreadsheet. 1. Incomplete Employees Home>Incomplete Employees. This report shows you the employees with missing required fields. Hire Date and ACA Classifications are required fields when it comes to ACA reporting. You are able to download this report to Excel, fill out the missing information, and re-import it into the system. 2. ACA Missing Data 15

16 Home>ACA>Manage Employee>Not Classified. This will drop you down into ACA>ACA Classifications. From here, you are able to either bubble fill in the missing ACA Classifications for employees or you can download the employee census to import the categorization. Exercise 6.1: Adding Missing Data Go to HOME >INCOMPLETE EMPLOYEES > DOWNLOAD TO EXCEL Fill in the missing information on the excel spreadsheet (DOB, Hire Date, ACA Classification). Re-import this information into the system using the same process that we went through on the employee import. Chapter 7- Assigning ACA Plan values Chapter Objectives: Define the importance of assigning ACA Plan Values Assign the ACA plan values so the proper codes are populated on Line 14 Each one of your medical plans needs to be assigned a value which will be used to derive codes for Line 14 of the 1095-C. We need to know certain things about the plans: Self-Funded: This will automatically be checked if the plans were marked as self-funded when the benefit was added. This tells the system to populate Part III of the 1095-C, or if the group is a small employer to produce the B series form. Enforce ACA Eligibility: A check within the system that allows Employee Navigator to calculate the correct eligibility dates for different enrollments. If this is checked, we are telling the system to look at an employee s ACA Classification before looking at the plan eligibility. This is enforcing ACA Classifications. Provides Minimum Value: A plan is minimum value if it covers at least 60% of the cost of benefits expected to be incurred under the plan. Provides Minimum Essential Coverage: MEC includes any major employer-sponsored medical plan, including retiree-only coverage, such as a retiree-only health reimbursement arrangement (HRA) Is Low Cost: Allows the system to simplify the calculations performed for affordability. There can be more than one low-cost plan. Spouse Coverage Excluded: When the plan does not offer the spouse coverage. Children Coverage Excluded: When the plan does not offer the child coverage. Conditional Spouse Offer: A conditional offer is an offer of coverage that is subject to one or more reasonable, objective conditions (for example, an offer to cover an employee s spouse only if the spouse is not eligible for coverage under a group health plan sponsored by another employer). Conditions attached to an offer may impact the spouse s eligibility for a premium tax credit. Exercise 7.1: Assigning ACA Plans You will now assign the ACA Plan Values for Life of Pie. Go to ACA>Assign ACA Plans. 16

17 On the 2015 Base Medical Plan Check: Enforce ACA Eligibility, Provides MV, Provides MEC, Is Low Cost, Children Coverage Excluded, and Conditional Spouse Offer. On the 2016 Base Medical Plan Check: Enforce ACA Eligibility, Provides MV, Provides MEC, Is Low Cost, and Children Coverage Excluded. On the 2015 and 2016 Buy-Up Plan Check: Enforce ACA Eligibility. We are enforcing ACA Eligibility on this plan even though it is not the low cost plan because we want to be sure that ACA Classifications are being enforced first and then plan eligibility. Note: If you have Dental, Vision, or HRA plans added onto the system you will also see them on this page. You are able to enforce ACA eligibility on these plans, so that when your Variable Hour employee become eligible, all of these plans will open up for them. These plans will not be reporting on using the 1095 form. Chapter 8- Measurement Periods Chapter Objectives: Identify the measurement method being used and the purpose of setting measurement periods We are using the Look-Back Measurement Method to determine if your variable hour employees have worked enough hours to be considered eligible for benefits. This is a measurement period that is between 3-12 months, where we measure to see if a VH employee works 30+ hours a week and must be offered coverage. We currently only support a 12-month measurement period for your ongoing employees. If, during that measurement period, an employee works 30 hours or more per week (or 130 hours per month) on average, then that employee becomes eligible for coverage (the VH employee is treated as an FTE) during a subsequent coverage period, called a stability period. Employers may also use an administrative period between the measurement and stability periods, where the hours that the employee worked are calculated and coverage is offered to eligible employees. NOTE: If a VH employee works enough hours to be considered eligible for coverage, their ACA classification will NOT change. They will continue to be a VH employee who is eligible for their stability period, and will continued to be measured for their next stability period. An employee s ACA classification will only change when there is a change in employment. New Hire Measurement Period- For newly hired VH employees, they will have a different hire date then ongoing employees. Their measurement period will start the first of the month after their hire date. You are able to select a measurement period other than 12 months for an employee s new hire measurement period, but 12 months is recommended. Ongoing Measurement Period- This is for employees that have been employed for more than one stability period. Their measurement period will coincide with open enrollment. Stability Period- The period in which the employee is "locked" in his status based on the hours worked in the preceding measurement period, regardless of how many hours the employee actually works in the stability period. This means that and employee in their stability period is considered eligible even if their hours drop below the 130-hour threshold. It is used for ongoing employees once they have been employed for a full measurement period. 17

18 Administrative Period: The optional period during which an employer can gather and analyze data to determine which employees are full-time, notify of eligibility, and enroll eligible employees. The administrative period can be no more than 90 days. You are able to select a period of time between 1-3 months on our system. For a VH employee in their New Hire Measurement Period, coverage must be offered within 13 months of their hire date, you are unable to select a New Hire Measurement Period of 12 months and an administrative period of 2 or 3 months. You are able to select a measurement period of 12 months and an administrative period of 1 month and it is compliant. Exercise 8.1: Setting-Up Your Measurement Periods Go to ACA> Measurement Periods New Hire Periods: Select a 12 month measurement period, and a 1 month administrative period. Stability Periods: Select September as the beginning month and a 2 month administrative period. Save Once a measurement periods have been set, they can only be changed through a data fix on Employee Navigator. Be sure you are setting up measurement periods up correctly. Chapter 9- Importing Hours Chapter Objectives: Define an hour of service and what hours need to be imported Import hours into the system Hours will be used to determine if your VH employees have work enough hours to be considered eligible for benefits. The hours worked are used in conjunction with your measurement periods above. Employees who work on average 130 hours a month or more during the measurement period must be offered affordable coverage. What is an hour of service? An hour of service is defined as each hour for which an employee is paid, entitled to payment, for the performance of duties to the employer; and each hour for which an employee is paid, or entitled to pay, but no duties are performed due to vacation, holiday, illness, disability, leave of absence, layoff, jury duty, or military duty. Federal regulations exclude volunteer, student employee, and member of religious order hours. How are hours determined when employees aren t paid hourly? It may be difficult to determine hours when employees aren t paid on an hourly basis. An employer may use one of the following methods to determine hours worked: Count the actual hours Use a days worked equivalency: 8 hours = 1 day Use a weeks worked equivalency: 40 hours for each week 18

19 Employers cannot use one of these methods if it will result in the understating an employee s hours. For example, if employee works 3 10-hour days, the employer cannot use the days worked equivalency method because that would result in 24 hours of works rather than the actual 30 hours. In some cases, even these methods don t provide enough information for those hours that aren t simple to track. Until further guidance is issued, employers are required to use a "reasonable" method to track these hours. For example, it would not be reasonable to fail to consider travel time for a sales person who is paid on commission only. Hours need to be imported for all of the Variable Hour employees. You are also able to import hours for your Ineligible and Eligible employees if you have those hours. Should monthly or pay period hours be imported? The system is configured to import monthly hours in order to calculate the average monthly hours over the measurement period. In some instances, your payroll system may only have hours worked for each pay period, so you will need to get the report from your Time and Labor system. We have a monthly and daily import template in place to import the hours. Common errors that you can receive when importing our hours spreadsheet: 1. Messed Up Worksheets a. File will not upload, and no records will be imported 1. Worksheet name 'Output' containing the hours data does not exist. The worksheet name on your imported spreadsheet must be named 'Output' just as it is on the provided templates. We recommend using our templates to load in hours, however, if you would like to use your own, the worksheet must be named 'Output' 2. Unable to Read the Spreadsheet: File will not upload, and no records will be imported Column Headers don't match template Month names are spelled incorrectly Non-numeric value in the Hours Worked column Date that is not formatted correctly 3. Failed Records: Valid records were processed, and some records contained errors and could not be processed SSN on file doesn't exist in the company Hours Worked information, but no date/month identified as to where the hours should be applied For more information on Managing Hours, please see the following article: ACA: Managing Hours. Exercise 9.1 Go to ACA>Manage Hours>Import Hours Use the monthly hours import template provided. Click to Import the File. 19

20 Chapter 10- Dashboard and Report Management Chapter Objectives: Manage Eligibility on the Dashboard Understand the information that is being pulled on the New Hire and Stability Report We have created a New Hire and Standard Stability Dashboard to help you track employees. The dashboard displays employees who are classified as Variable Hour. New Hire Dashboard The New Hire Dashboard is where new hire eligibility is managed for variable hour employees in their initial measurement period. 1. The HR Pending Action lists employees who have ended their measurement period. Employees who have worked enough hours to be eligible for coverage are listed as eligible, and selecting Finalize as Eligible will send an (if on file) inviting the employee to enroll. Employees who did not meet hours will display as Ineligible, allowing validation that hours were complete and accurate. Finalize Ineligible will remove the employee from the list. The option to override eligibility (not recommended) or add additional hours is available. 2. The Pending Employee Enrollment list lets you know the employees who are eligible for coverage, but have not yet enrolled. From this list you have the ability to send an employee a reminder to enroll in coverage. 3. The In Measurement Period list contains all employees who are in their initial measurement period. 4. The Part Time Trending Eligible list shows employees that have the ACA classification of Part- Time, but based on their hours are trending eligible. This is useful for those employers who want to manage the employee hours to ensure they do not exceed 30 or those who have incorrectly classified an employee as ineligible, when they should be variable. Standard Stability Period Dashboard The Standard Stability Period Dashboard is where eligibility management is completed for the next stability period for the variable hour employees. You are able to see employees who have been employed for a full measurement period and are currently being measured. After measurement period ends, any employee who did not pass their measurement period and is currently enrolled and will be losing coverage are listed separately because it is important these employees know they are not eligible to continue coverage. Based on the total hours during the measurement period, employees are either listed as Eligible or Ineligible. From this list you are able to finalize the eligibility status, override the eligibility status (not recommended), or add hours if the hours were not correct or complete. New Hire Report and Ongoing Report: These reports are an expansion of the information provided on the New Hire and Standard Stability Period Dashboards. 20

21 1. Trending Eligible- based on the number of months hours have been imported, the employee has an average of 130+ hours. 2. Trending Ineligible- based on the number of months hours have been imported, the employee has less than 130 hours. 3. Eligible- Employee has completed their measurement period and has been determined eligible for coverage. 4. Ineligible- Employee has completed their measurement period and has been determined ineligible for coverage. Example of a Variable Hour Employee A Variable Hour employee is hired on 9/5/2015. The company has chosen a 12 month measurement period, with a 1 month administrative period. This means that the employee s measurement period will begin 10/1/2015 (first of the month after the hire date) and last until 9/30/2016. His administrative period will be from 10/01/2016 to 10/31/2016. During his measurement period, the employee works an average of 130 hours a month. During his administrative period he needs to be offered coverage because he passed his measurement period. It is important to note that the employee ACA classification does not change after he passes his measurement period. The employee will continue to be a Variable Hour employee, but now he is a Variable Hour employee who is eligible for coverage. Exercise ELIGIBILITY DASHBOARD>NEW HIRE PERIOD You will notice that some employees on this list are marked as past due HR PENDING ACTION. What does this mean? The administrative period for these employees has passed. You will want to finalize or override these employees appropriately so that can be reported on appropriately. You will notice that one employee, Michael Quirk, is in his administrative period. You will want to finalize him or override his eligibility appropriately. 1. Michael Quirk- Finalize Eligible Status (employee will be receiving a form for 2016 reporting). Because his eligibility is past due, his eligibility will be back dated. 2. Michael Smales- You still need to add 3 months of hours for Ian. Manually add these hours by selecting Add Hours. Add 120 hours for July, 90 hours for August, and 100 hours for September. After hours have been added, finalize Ineligible Status (employee will not be receiving a form for 2016 reporting). Because his eligibility is past due, his eligibility will be back dated. 3. Ian DeVita- Finalize Eligible Status (employee will be receiving a form for 2016 reporting) 4. Henry Navigator- Finalize Eligible Status (employee will be receiving a form for 2016 reporting) 5. Marco Polo- Finalize Ineligible Status (employee will not be receiving a form for 2016 reporting) Once you have finalized the status of these employees, the employees that are eligible for enrollment will be moved to Pending Employee Enrollment. You need to notify these employees manually that they are now eligible for enrollment. The system will not automatically notify them. 21

22 Chapter 11- Enrollment Chapter Objectives: Identify what the enrollment is used for on the 1095 form Identify the different ways to get enrollment information into the system- both the Historically and the through the benefit Line 16 of the 1095-C identifies if employees were actually enrolled in coverage and the months they were enrolled in coverage. As long as you are using the system for all eligible employees, you do not need to re-import enrollment. The system will use the historical enrollment to determine the necessary codes. If you began using the system to manage your benefits mid-year, you will complete two imports. First, import most recent election as the current election via the import tool (Home>Employees>Import Employees and Enrollment). Next, use the new import prior enrollment tool to import data for historical elections prior to your effective date. If you are only using us for ACA reporting, you are able to only use the historical import tool to get enrollment information into the system. For both the Historical Import Tool and the Ben Admin Enrollment Import you will first need to build the medical plans that you are importing the enrollments for first on the system. You do not need to import a declined enrollment. We are able to determine if coverage was offered without having the declination imported. Historical Import Tool The ACA Prior Enrollment import template can be located at Home>ACA>Historical Import Tool>Import Enrollment History and include the following fields: Social Security Number, First Name, Last Name, Plan Name Coverage Start Date Coverage End Date. The coverage start and end dates are the dates that the employees were enrolled in the coverage. You always need to have a coverage start and end date on the file. You are able to view the details of the employees enrolled in a given month, including the dependent enrollment history if it is a Self-Funded plan. You are able to overwrite files using the historical enrollment tool. If you overwrite a file, you are replacing the information from the old file that you are overwriting with the information on the new file you are importing. Ben Admin Enrollment Import Imported enrollments are created as current enrollments, meaning that you can only import enrollments into an active plan using this template. You will be using the Basic template (located under our Import Employees and Enrollment tab) to import enrollments into the system. To import the file go to Home>Import Employees and Enrollment>Start a New Import. You will be importing enrollments into the system. 22

23 Exercise 11.1: Importing enrollment information using the Historical Import Tool ACA>Historical Import Tool>Import Enrollment History Start New Import using the File Provided 1. What are you Importing?- Employee Only Enrollments 2. Map- Make sure the column headers match the dropdowns 3. Audit: 2015 Base Medical Plan 4. Commit 5. Go back to Summary to view the enrollments that have be imported using the historical import tool Chapter 12- Import Low Cost Plan Cost Chapter Objectives: Identify when to use the low cost plan cost tool This tool allows the import of the low plan cost which can be used to insert the employee only monthly coverage cost instead of using the system calculation. You would use this tool if the system cannot accurately calculate the cost of coverage to report on Line 15. After the monthly cost of coverage is imported, the system is using this value to perform the standard code calculations to determine offer and affordability. Importing a blank for a month will remove the imported cost and revert back to the system generated calculation. Exercise 12.1: Importing Low Cost Plan Cost ACA>Import Low Cost Plan Cost>Import Start New Import using the File Provided 1. Import Options- Change file name to Life of Pie Low Cost 2. Map- Make sure the column headers match the dropdowns 3. Audit 4. Commit 5. Go back to Summary to view the costs that have be imported using the Low Cost Plan Cost tool. When the 1095 forms are generated, expect the imported costs to appear for George Bass and Jackie Brody. Chapter 13- Assigning Safe Harbors Chapter Objectives: Identify when to assign Safe Harbors 23

24 An ALE needs to know if health coverage is affordable for its full-time employees because it determines whether an employee can receive a premium tax credit, and whether the employer is subject to a penalty. If the employee s required contribution to the employer-sponsored plan does not exceed 9.66% of the employee s household income, then the plan is considered affordable. However, it is difficult to determine an employee s household income. For this reason, there are three safe harbors that employers can use to determine affordability. W-2 Safe harbor: The W-2 safe harbor uses the employee s annual W-2 wages (Box 1 value) and treats coverage as affordable if the employee contribution for the year does not exceed 9.66% of the W-2 value. Rate of Pay safe harbor: The Rate of Pay safe harbor uses the employee s rate of pay and treats coverage as affordable if the employee contribution for the year does not exceed 9.66% of the employee s rate of pay. Federal Poverty Line safe harbor: The Federal Poverty Line safe harbor uses the federal poverty line for the year ($11,880 in 2016) and treats coverage as affordable if the employee contribution for the year does not exceed 9.66% Our Assign Safe Harbor tool allows you to assign these three safe harbors to groups of employees. Safe harbors can only be assigned by reasonable grouping. If an employee is assigned a safe harbor, the code will be reflected on line 16. It is important to note that if an employee is enrolled in coverage they will receive a code 2C (Employee enrolled in coverage offered), not a safe harbor code. Tip: For commissioned employees, an employer will most likely use the W-2 safe harbor to determine affordability. Exercise 13.1: Assigning Safe Harbors Go to ACA>Assign Safe Harbors. Safe Harbor: Select Rate of Pay Safe Harbor. Assign To: Everyone Assign You can now expect that the 2H code will populate on the form for the appropriate employees. If the cost of coverage exceeds 9.66% of the employee s rate of pay or if no compensation information is added, then the 2H will not be populated. Chapter 14- Completing Employer Settings The employee and company IRS forms require certain data elements to be included on the forms, for example, the contact name for employees to call will be entered on the employee s 1095-C. This selection collects the necessary company information as it pertains to the IRS filings. This data only applies to the IRS filings since this information may be different from the other company values stored in the company profile. The company setting can be added by navigating to Home>ACA> Part 1 Employer Information. If you are a member of an Aggregated Control Group using Business Units to report, check yes for Are you using business units to file for multiple EINs. You will then fill out the company information for 24