ACA Reporting

I am working on an ACA reporting project for a medium (?) sized company (the company probably has about 2000 employees – small to me) which under the terms of the IRS is considered an ALE (applicable large employer).I’m just learning the lingo and the details about reporting healthcare. For me, the language is kind of obtuse, but after working through the data, some of the verbiage is starting to make sense.

When you first start reviewing the on-line “papers”,  it’s a lot of material to pick up. Only by working through the reporting does it start to make sense. I have to actually work with the data and play with them to start to see what might be needed for the reporting. I can’t just read the instructions and go, “Oh, this is what I need.” I kind of have to play with the numbers before I can go, I’m going to need x, y, z in order to report the numbers.

This is what I know so far: for ALEs (employers with 50 or more full time-employees – or full-time equivalents), they use forms 1094-C which is sort of like a summary transmittal form and 1095-C which is a form for each full-time employee. Anybody who has been a full-time employee at any time in the year must have one of these forms. To repeat, only full-time employees need this form; part timers do not require this form. Form 1095-B is what the insurers send to the employees but they don’t have to send to the employers.

Right now I’m working on form 1095-C. My company doesn’t do self-insurance, so I will not be filling out part III. Part I is basically rudimentary information such as name, address, SSN, employer name, employer address, employer identification number, and some other stuff. Part II will be the meat where I show for each month if we offered coverage and what type, the minimum employee cost for self and what I call reasons for “non-coverage” or “non-enrollment”. The offer of coverage are the 1 Code Series and for my company, they basically distill down to non-coverage and coverage (either self, self and spouse, self and dependents and family). I do have some basic questions such as what if we offer but they don’t enroll or since we offer coverage up to family, does that mean everybody gets the family 1 Code (1E)? By the way, you can use the offer codes (1B, 1C, 1D, or 1E) only if they get coverage for the entire month. So if somebody is hired after the first or is terminated sometime in the month, then the no coverage code (1H) would be used.

The minimum employee cost for self was easy: if you used codes 1B, 1C, 1D or 1E, then you would enter the minimum cost. For my company, they had the numbers for this so this was very easy to fill out.

For the last piece of Part II, I call it the reasons for non-coverage because the term “Safe Harbor” is deceiving. Our HR VP said the company does not qualify for safe harbor and so we wouldn’t report in this section, but she is thinking of another “Safe Harbor”. Once she read through the instructions, she realized, “Okay, yeah, we do have to fill out.” The way I see “Safe Harbor” in the third section of Part II is that you give reasons for non-coverage. Those reasons could be: a) person was not employed (until later on in the year); b) person quit or was terminated; c) the person was hired during the month and thus did not work for the full month; and d) the person is in a “waiting period” or testing period before coverage actually have to start.

This piece of Part II uses the 2 Code Series. I  have mapped out what I think are the corresponding 2 Codes for each 1 Code. If we offered (1B, 1C, 1D, or 1E) and an employee enrolled in healthcare the code would be 2C. For non-coverage or no offer (1H), we use 2A if the employee was not employed at any time for the month, 2B for when the employee was terminated that month, and 2D if the employee was hired during that month or are in the Limited Non-Assessment Period which I understand as a waiting period (typically 3 months). Again, I have some questions for this section.

On my spreadsheet, I have the full-time folks who worked for the entire year in 2015 already done. They were easy to do. I have done most of the identification of 1H and figured out how to set up the spreadsheet to identify points when employee gets hired or is terminated. I still have quite a bit of questions but I think I have made great strides on getting this completed.

Another thing I need to tackle is creating a form that will merge with the Excel data so that it will look like a filled out IRS form. There is no way I’m going to fill out by hand 2000+ forms. But I have an idea and have already started creating the form.