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ACA FAQ - Eligibility

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If the initial measurement period is set to the first of the following month is that tied to setting ACA eligibility or will it trigger from assignment date?

You can determine in Eligibility and in the ACA Companion if you want the initial measurement period start date to be the assignment start date or first of the following month (following their start date).

 

 

If we can supply a list of Employee IDs who declined coverage to Avionté, can a script be created to insert the required Contribution setting?
There will be an import available for you to provide additional information. More will be needed than just the Employee IDs, but once the import is complete, Avionté will be able to bring that data into the system.

 

 

Why are there unexpected employees on the ACA Full-Time without Offer counter? They shouldn't be eligible.

The start date on the employee's deduction and benefit may be earlier than the most recently calculated hire date. The conditions that result in an employee being returned by the counter are as follows:

 

  • ACA eligibility must be "Yes"

  • The Employee Status must have the ImpliesActive Property set to "True"

  • The  must be within the number of days specified by the AdvanceWarningTimeFrame Config Option

  • Must not have an offer of coverage in the Employee Plan Details section of the Companion App, or no offer since they most recently were set to Yes for ACA Eligibility.

 

 

All of our employees are eligible for our insurance on their start date. We offer an MEC plan but not an MV plan. How do we track our employees’ full-time status within Avionté?
Avionté uses the look-back measurement method, typically with a 12-month measurement period. The 12-month measurement period allows the staffing company the longest “test period” to determine if the employee is full time and should be offered coverage and will count for penalties and require reporting.

The IRS does not require that employers document their measurement method, however, doing so may help an ALE (Applicable Large Employer) demonstrate their compliance, therefore tracking is recommended even if insurance is offered to all employees.

 

 

We first offered coverage effective 2/2/17. If someone worked at the beginning of 2017 but ended prior to the insurance being offered, do they need a 1095-C and how should their ACA eligibility be marked?
If the employee was full-time for an entire month of the year then they would be considered ACA eligible and require a 1095-C.


Example

If you have an employee that is full-time in January for the entire month and then terminates in February prior to being offered insurance, a 1095-C would be provided to that employee since they were full time in January. If no coverage was offered, they will still require a 1095-C. If the employee declined coverage you will still need to report that the offer was made by entering in a contribution and they will still require a 1095-C.

 

 

If an Employee is hired full-time and is coded as ACA Eligible, but their employment is terminated prior to the 90 day threshold, do we update the EE's eligibility status to "No"?
The status should not be changed. It should remain ACA eligible "Yes" unless there is a qualifying break in service.

 

 

If an EE is hired full-time, is coded as ACA Eligible, and works most of the year (over 90 days of employment), but their assignment ends, do we update the EE's eligibility status to "No"?
No, you would not need to update their eligibility status. If they have a qualifying break in service, Avionté will automatically change their status back to "Undetermined" so they are treated as a new hire if they return to employment with you. However, it will be important to terminate their assignment in a timely manner.

 

 

If an employee has a break in service, will Avionté automatically change their eligibility to "undetermined"?
Yes, in versions 14.1 and newer, Avionté will capture qualifying breaks in service and will populate the information (start/end date and reason) to the grid in the measurement window.


Versions older than 14.1 do not have the most current qualifying logic. If you are using one of these older versions, you should manually track breaks in service.

 

 

If we only offer MEC and offered to everyone from day one, would Avionté generate a 1095-C even if the employee's ACA eligibility is set up as "undetermined"?
IF ACA eligibility is set to "undetermined," the system will not create a 1095-C the employee.


Any employee (either full time or variable hour) who enrolled in your MEC should have been set to "Yes" at that time. ACA eligibility "Yes" is a trigger to generate a 1095-C. You can use the ACA Companion Census AQ to locate employees set to "undetermined."

 
In addition, you would not want to change an employee back to "Yes" after a break in service as that would be inaccurate. If, at any point, they were set to "Yes," they will have a 1095-C generated and you will not have to switch them back to "Yes."

 

 

After an upgrade, how are "undetermined" statuses changed to "no" in order to let the system track and convert to "yes" as they become eligible (+/- 8,000 employees)?
Avionté can run an update, but it will update the eligibility for all employees in your system to "Yes," regardless of their status. You will then have to manually change those who are not eligible back to "No" as needed.


Usually the eligibility status is manually set upon hire/placement of an assignment. If the employee is set to "No" they will change to "Yes" if they finish their measurement period at full-time, but will not go from "Yes" to "No" if determined to be non-full time.

 

 

If we enroll an employee in an MEC plan, and they later have a break in employment, and their plan is cancelled due to lack of payment of the plan, should we inactivate this deduction code?
Yes, if a qualifying break in service occurs you will want to inactivate the deduction code. Avionté doesn’t track non-payment. It is recommended that you consult with your broker.

 

 

What is the difference between "initial" vs "standard" measurement period?
Initial measurement periods are for new employees. Standard measurement periods are for on-going employees.


Note: If an employee is eligible but declines coverage during the initial measurement period, they must be offered coverage again (if their eligibility continues), at the end of the standard measurement period.

For more information, visit https://www.irs.gov/irb/2014-41_IRB/ar10.html

 

 

We have a 60-day waiting period before enrolling. How is the system determining 2D (employee in non-assessment period)? 
2D is determined by the deduction setup and start date and will populate in those months. The system also looks at the property for length of initial measurement to determine if the EE is in their initial measurement period. You may use the Employee Extra value to override if needed.

 

 

ACA Companion Census AQ shows many "undetermined" eligible employees that are inactive or DNA. Do I need to worry about them?
If the employee was ACA eligibility "Yes" at any time during the year, they would get a 1095-C, regardless of current status. If the employee is currently inactive or DNA and is set to undetermined, you can leave them undetermined.

 

 

Most of our employees have left or have been hired on by clients. However some internal employees have declined our offer due to spouse coverage. Does the vendor send 1095-C or are we required to issue 1095-C. Also, if we have provided coverage and they have not contributed do we need to show that under contribution?
If you are the employer on record you are responsible for sending the 1095-Cs. If you have an employer contribution, then you will want to record this on the Contribution tab. For every month that you were the employee, you must provide a 1095-C.

 

 

Using the ACA  Companion CensusAQ, how are we able to determine "new" employees that are eligible for benefits that weren't previously on the list prior or haven't previously waived benefits without looking at every employee's file on the list?
The Hire Date column can be used. However, it may be easier to track this via the ACA Full-Time without Offer counter.

 

 

If we know an assignment is 40 hours a week but only lasts for 3 months, is the employee considered full-time? Are they ACA eligible and do we have to offer insurance?
The law states that if the employee is expected to be working full-time they must be set to ACA eligible.


Factors to consider include, but are not limited to: 

  • Whether the employee is replacing an employee who was or was not a full-time employee
  • The extent to which employees in the same or comparable positions are or are not full-time employees
  • Whether the job was advertised, or otherwise communicated to the new hire or otherwise documented (for example, through a contract or job description), as requiring hours of service that would average 30 (or more) hours of service per week or less than 30 hours of service per week.

 

The final determination of full time vs. variable-hour employee is up to the employer.

 

If an employee became eligible for insurance on March 1st and they were working, would they continue to show up in each subsequent month? 

Yes. It's displaying months an employee is eligible, not just the month an employee became eligible.

 

What if a full-time employee's hours dropped to part-time?

Once an employee is no longer considered eligible for an offer, they would no longer be counted. The system recognizes an employee to be considered ineligible after a valid break in service, after their termination date, or after their stability period ends following a completed measurement period determines them non-FT.

 

If we have an employee that has a break in coverage due to being in between assignments does this need to be documented? How would we list this along with the reactivation of coverage?

If the employee has multiple offers of coverage due to breaks in assignments you will want to document all offers with the correct start/end dates in the ACA companion.

 

If we are determining everyone full time when placed on assignment, do we need a measurement period set up?

Yes, the eligibility data is required information in the ACA companion.  Most of it will come from the set up you already have entered in the core application.


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