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ACA FAQ - General

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What is the Affordable Care Act?
The ACA is the most sweeping, comprehensive expansion and regulatory overhaul of the United States health care system since Medicare and Medicaid were created in 1965.


Signed into law on March 23, 2010, the ACA is designed to increase the affordability and rate of health insurance coverage for Americans, and reduce the overall costs of health care for individuals and the government.

 

 

What has already happened?
Since ACA became law in 2010, a number of key changes to our nation’s health care system have been implemented:


2010

    • Eliminated lifetime limits on insurance coverage
    • Prohibited denying insurance coverage to children based on pre-existing conditions
    • Extended coverage for young adults by allowing them to remain on their parent’s plan until age 26
    • Prohibited insurance companies from rescinding coverage based on technical errors on consumer applications

 

2011

    • Free preventive care is provided for seniors
    • Seniors who reach the coverage gap (“donut hole”) receive a 50% discount when buying Medicare Part D covered brand-name prescription drugs
    • Established the Center for Medicare and Medicaid Innovation (CMMI)
    • Established the Community Care Transitions Program to help high risk Medicare beneficiaries who are hospitalized avoid unnecessary readmissions by coordinating care and services

 

2012

    • Established a hospital Value-Based Purchasing Program (VBP) in traditional Medicare that offers financial incentives to hospitals to improve the quality of care
    • Established “Accountable Care Organizations” (ACOs) that provide incentives for physicians to join together coordinate patient care and improve outcomes

 

2013

 

    • Health Insurance Exchanges opened for low to middle income Americans to make it easier for them to shop for health insurance. Those making over 400% of the poverty level can shop on the exchange but will not receive tax credits or discounts. The insurance purchased on the exchange doesn’t go into effect until Jan 1st, 2014.

    • A health insurance exchange was set up by each state; exchanges were set up by the federal government when a state decided not to run their own exchange.

    • Tax credits, discounts on out-of-pocket costs, tax breaks and other subsidies were made available on the exchange.

    • ACA increased (7.5% to 10%) the threshold at which medical expenses, as a % of income, can be deductible.

 

2014

 

    • The Individual Mandate: There is a tax starting at 1% of your income or $95 and raising to 2.5% of your income or $685 by 2016 for individuals. For a family, it’s capped at $285 in 2014 and rises to $2,085 by 2016. It cannot exceed these amounts. This helps pay for emergency and future coverage you may need. The tax penalty is paid on your tax returns. This is referred to as a “tax” not a “mandate”.

    • You can no longer be denied for preexisting conditions.

    • The only factors that can affect premiums of new insurance plans starting in 2014 are income, age, tobacco use, family size, geography, and the type of plan bought.  This applies to all plans sold through the individual's states health insurance marketplace.

    • All new plans sold must include Ten Essential Health Benefits.

    • No Annual dollar limits on coverage.

    • Congress must shop on the health insurance exchanges.

    • Pharmaceutical companies are subject to a new tax.

    • Insurance purchased on the health insurance exchange / marketplace goes into effect.

    • Employers will be able to shop on the health insurance exchanges for employee insurance.

    • Tax credits, tax breaks and help with up-front costs are available to those struggling to pay for insurance.

    • Insurance companies are taxed based on their market share.

    • Small Business Employers can shop for employee coverage on the health insurance exchange.

 

2015

 

    • Employers with over 50 full-time equivalent employees must offer health insurance.

    • Doctors’ income is based on quality of care not quantity of care. This is a vast simplification of the actual documentation in the bill. It is a protection from the current fee-for-service payment model.

 

 

What Avionté reports ensure that ACA reporting is accurate?

ACA Census AQ, Employee deduction/contribution list AQ, Comprehensive Assignment AQ.

 

 

Is there an Avionte report that I can run that will show what info will be reported on an employee's 1095-C? 

Our reports are being updated to look at the ACA Companion application data. ACA Census AQ will show eligibility and deduction/contributions, Employee deduction contribution list - you can filter to HC plans, Comprehensive assignment AQ - vets out the start and end date of employees.

 

 

Is there an import in place again with ESC/PAI for those that elected coverage and their dependant info?

There are several ESC imports. If you are currently using an ESC import, it will continue to be in place with the new companion. For those offering a direct pay plan, ESC provided a file at the end of the year and Avionté created an import to pull that data in. This import will still be in place, so you will still be able to use that same import this year from ESC.

 

Regarding payroll, do we have to do anything to close out 2016, or is it just ready Jan 1, 2017?

Unlike other systems, in Avionté you do not need to close out end the year or quarter end. The accounting period needs to be closed each week. For taxes, it is driven of off check date. Consider if you have filed the reports. Many times, at the end of the year, it will be a backdate situation. We do have a process in the weekly process that flags as "complete." Once you feel confident that your numbers are not going to change, you can flag as complete. This stops you from generating the feed again. Most clients do NOT flag as complete for other quarters. Only quarter four drives the W2s. A date is posted and you are unable to make any changes unless that date is removed.

 

 

This year, we used a PEO, but we're going to be reporting and generating the 1095-C & 1094-C through Avionte. Would I need the PEO's FEIN number to be reported on 1094-C & 1095-C since they pay the employees and issue the W-2's? 

The PEO should be filing the form for you.

 

We have our PEO set up in Avionté as a supplier and we continue to do everything in Avionté put under the PEO supplier.  If I put in the PEO's FEIN number under their ACA setup for that supplier will it generate the 1095-C & 1094-C with their FEIN number?

If you are tracking in Avionté, you can report on it.

 

 

We don't have the ACA package, however, it was my understanding that we could still upload our own spreadsheet through Greenshades for our 1095 submittal to the IRS. Is this correct, and if so, where can I find instructions on how to format the spreadsheet correctly? 

If you wish to use the spreadsheet that Greenshades has created, log into Greenshades and download the formatted spreadsheet. You will have to add the data manually.

 

I'm going to be using greenshades to process my W2s. How do i get the info over to Greenshades?

Use the Greenshades XML. During the weekly process, generate Greenshades. There is error checking involved as well. When you are outsourcing to Greenshades you will need to create year-end forms and then you will be able to upload the forms. There are a number of steps for verification and then you will be able to email to your employees. For more details, we have a recorded webinar (contact your Client Manager) regarding the use of Greenshades and multiple articles in the Integrations - Payroll & Taxes section.

 

 

The yearly ESC file for direct bills is available.  Do we put a ticket in to have this imported?

You can do it yourself. It is the ESC standard import. Under the AQ tab of Admin Tools > Reports, you can search for the ESC standard import. If you do not see this a ticket is needed to request the deployment.

 

We are going to electronic W-2's this year.  We have consent on file for those employees that have opted to receive them electronically.  What steps do we need to do to give them access to their electronic W-2?

We can post the eW-2 on the portal but you must get consent from your employee. After you run your w2 thru Greenshades the W2s will be posted on the portal after you flag as complete. The system will post the W2s with consesnt to the portal. Visit the Producing W-2s article for details.

 

What is the individual mandate? Who is required to have health insurance?
Beginning in 2014, all Americans – with some exceptions – are required to have health insurance coverage or face a penalty. Qualified health insurance plans (QHP) may include:

  • Government-sponsored plans, such as:
  • Medicare or Medicaid
  • Children’s Health Insurance Program (CHIP)
  • TRICARE
  • Veterans health care programs
  • Employer-based or sponsored health care plans
  • Individual private coverage
    If you don’t have insurance and don’t meet one of the exceptions described below, then you will be eligible to purchase coverage through your state-based exchange or marketplace beginning October 1.

Penalty
If you are required to have health insurance, but do not obtain coverage in 2014, you will be assessed a penalty or fee that equals 1% of your yearly income or $95, whichever is higher. The fee for uninsured children is $47.50 per child. The fee increases to $325 or 2% of yearly income in 2015. The fee is assessed when you file your federal income tax return.


Exceptions
Uninsured individuals will not be required to buy insurance or pay a penalty if:

  • They are low income and premiums are considered to be unaffordable (defined as premium cost that exceeds 8 percent of household income)
  • They are not required to file a federal tax return because their income is too low
  • They would qualify under new income limits for Medicaid, but their state has chosen not to expand Medicaid eligibility
  • They are uninsured for less than 3 months of the year
  • They are a member of a federally recognized Native American tribe
  • They participate in a health care sharing ministry or belong to a recognized religious sect that has religious objections to health care
  • They are granted a hardship exemption (applications for hardship exemptions will be available through the exchanges)

 

 

Is there a certain number of employees that must accept our health plan in order to offer it?
The ACA mandates an offer of coverage and does not have participation requirements.

 

 

What forms need to be supplied by a 3rd party payroll service to our company's employees?
Because Avionté does not know that 3rd party's payroll information as it may be specific to your agreement with the provider, all questions regarding 3rd party processes should be directed to them.

Avionté cannot advise on legal issues. We recommend that you consult with your accountant, legal representative, or broker. Avionté is available to assist with setup once determinations have been made.

 

 

Some of our employees are tracked with Essential Staff Care (ESC) can we import this information into Avionté?
Avionté has partnered with ESC to provide an import feed into the Avionté suite. Contact your Client Manager and request the feed setup. Imports from other sources may be possible. Please create an Avionté Support Center ticket to discuss this possibility.

 

 

Should we use the contribution or the deduction section for the employee’s portion of insurance cost? In the contribution section how do you indicate that they declined?
Both the deduction and the contribution sections are used when setting up insurance for an employee.


Payroll > Deduction - The deduction section records the amount deducted from the employee’s pay.


Payroll > Contribution - The payroll section covers the employer contribution and/or employee declination.


A declination of offered coverage is recorded at the Employee level in Payroll > Contribution. Select the appropriate healthcare plan and enter $0 contribution, include the start and end date of the time frame this employee would have been covered. The rest of the information should be filled out as normal.


If no transaction exists for declination, an admin-level user must add it in Admin Tools > Transaction Types.

 

 

We entered every employee that declined under contribution, Healthcare Plan Non-qualified but now realize we should have entered some employees that declined as healthcare plan other qualified. Is it necessary to go back and change this setting?
The reason why the employee declined and/or lack of employee response is not required information, however, you may find it to be useful information internally. The important thing is that the declination was recorded as a $0 contribution and noted as a declination under the employee record.

 

 

Is a declination the same thing as receiving an offer?

A declination is receiving an offer and declining coverage.

 

 

Does Avionté offer a Decline Waiver eDocument? If it does not, how can we capture this?
Avionté does not have a standard declination waiver eDocument. The method of capturing this will need to be identified internally.

 

 

We were thinking of getting employees to complete an eDocument during hire process to either select interested in insurance or decline insurance to prevent the need to track down and get declinations at a later date once eligible. Any legal issue with this approach?
If you present an eDocument prior to offer of coverage, then the employee would still have to be given the option to take insurance when they meet eligibility.

Avionté cannot advise on legal issues. We recommend that you consult with your accountant, legal representative, or broker. Avionté is available to assist with setup once determinations have been made.

 

 

Our MEC (Minimum Essential Coverage) doesn't track the declines. How do we determine who declined so that we can enter the declinations?
Generate the ACA Census AQ and filter both the Deduction Name, and Benefit Name to "blank." Filter the ACAEligibilty to "Yes." Those that populate on the list will be eligible employees that had no deduction or benefit name recorded. This will assist with identifying which records need declinations recorded.

 

What is a 1095-C?

The 1095-C is a form employers and employees turn into the IRS to show proof of insurance. Much like the Form W-2 is used to determine whether or not you owe taxes, the IRS will use the information reported from your Form 1095-C to determine whether you (or your employer) may have to pay a fine for failing to comply with the Affordable Care Act. Applicable Large Employers (ALEs), or employers with 50 or more full-time equivalent employees, are required to send Form 1095-Cs to all full-time employees (those who work an average of 30 or more hours per week) as well as any employee who was enrolled in their health insurance plan.

 

The Affordable Care Act, or Obamacare, includes both the individual mandate and the employer mandate.

 

  • The individual mandate requires that most Americans have qualifying healthcare coverage or potentially face a fine.
  • The employer mandate requires employers with 50 or more full-time equivalent employees to offer healthcare coverage to their full-time employees or potentially face a fine. 

 

The Form 1095-C contains important information about the healthcare coverage offered or provided to you by your employer. Information from the form may be referenced when filing your tax return and/or to help determine your eligibility for a premium tax credit. Think of the form as your “proof of insurance” for the IRS.

 

 

If we have not set up any of the ACA parameters, can 1095-Cs be generated?
No. You will need to go through the process with a trainer and product specialist. Please enter an ACA Setup and Review ticket in the Avionté ticketing system. Please keep in mind that a recalculation (with a required minimum of 6 hours billable time) will be needed to review transactional history for the year.

 

 

If our healthcare plan goes into effect 1/1/2016, but 12/28/2015 is the start of that accounting period, what date do I use during report set up?
Your accounting period does not play a part in the report setup. The correct date to use is the date that your healthcare plan went into effect, in this case 01/01/2016.

 

 

If you have multiple suppliers, would you ideally enter the same information for all properties within each supplier?
Each supplier should be configured to reflect the healthcare offerings for that supplier. If all suppliers are identical, they can be set up with the same information.

 

 

What if the premium differs per employee in the same branch?
These settings can be modified to be employee-specific in the Employee Extra field. The coding used in Employee Extra will override both the branch and supplier (reverse hierarchy).

 

 

We have internal staff who have left and elected COBRA. Our insurance broker says that we have to report the COBRA coverage but since they were not on payroll and had no contributions, how do we create a 1095-C for those people?
COBRA is handled like any other deduction for Health Care coverage and is therefore documented in the deductions tab.


If a former employee of an ALE enrolls in COBRA coverage, the employer would indicate the offer of coverage on the 1095C form for all months that the employee was covered under the plan and for all the months they were enrolled in COBRA coverage.


Upon moving to COBRA coverage, the Line 15 cost of coverage reported should be changed from the lowest cost employee-only cost to the COBRA single premium amount. To ensure line 15 has the correct value use the employee-level line 15 override GSACA_1095CLine15Value to enter in the cost for COBRA.

 

 

What if the property GSACA_1095CLine16Value needs to be changed during the year?
Line 16 contains information regarding ACA’s safe harbor provision. https://www.irs.gov/instructions/i109495c/ar01.html#d0e1062


Configure this line by entering the safe harbor code and the "plan since date" (e.g. MM/YYYY.) This can be set at the supplier, branch or even Employee Extra level and will be reflected on reports.


To make changes, start a new line using ENTER separation and enter the new code and new since date.


Example: Safe Harbor
2F 01/2015
2G 12/2015

Avionté cannot advise on legal issues. We recommend that you consult with your accountant, legal representative, or broker. Avionté is available to assist with setup once determinations have been made.

 

 

We did not set up any contributions can we do a mass update so that all employees without a health deduction are set up with a contribution?
Please create an Avionté Support Center ticket for a situation like this. Our technicians will investigate your options. They may be able to run a script for you as long as all employees are on the same Health Care contribution.

 

 

One of our customers that we provide staff to is requesting ACA information about who we placed at their location.
The ACA Admin Fee can be used to provide additional information to your customer, however - providing information about specific employees could be problematic with co-employment law and/or HIPPA.


Avionté cannot advise on legal issues. We recommend that you consult with your accountant, legal representative, or broker. Avionté is available to assist with setup once determinations have been made.

 

 

Does the original contribution date change when an employee is rehired after a 13 week gap?
Yes, if a qualifying break-in-service occurs. This should be treated like a rehire and the employee will need to be reevaluated.

 

 

Do we have to terminate the employee for the system to catch a break-in-service or just termination of the assignment?
In order for the system to catch a break-in-service, the assignment will need to have ended. This can either be due to the assignment completion or employee termination.

 

 

What report shows the break in service?
The ACA Census AQ includes break-in-service data. Break-in-service information is also found in the Employee > ACA section in 15.2 and newer.

 

 

Why is the Insurance Effective Date used under the employee record?
The Insurance Effective Date is the date that you must have your employee on insurance to avoid incurring a penalty.

 

 

What is the deadline to submit the 1094-C/1095-C in 2016?
The original filing date was January 31, 2016, however, the date was updated (per Notice 2016-4) to March 31, 2016.

 

 

If we are paying for Avionté to produce 1095-C forms, is the electronic submission to the IRS included in that or do we need to do that another way?
Certain vendors support electronic submission to the IRS. Contact your Client Manager or a Product Specialist to discuss the options available.

 

 

If the ACA Status was changed by an employee, is this stored in the Employee Log?
Yes, any manual change to an employee’s ACA eligibility status will be viewable in the employee audit log.

 

 

What is considered the Aggregated ALE Group?
According to the IRS, companies with a common owner or that are otherwise related under certain rules of section 414 of the Internal Revenue Code are generally combined and treated as a single employer for determining ALE status.

If the combined number of full-time employees and full-time-equivalent employees for the group is large enough to meet the definition of an ALE, then each employer in the group (called an ALE member) is part of an ALE and is subject to the employer-shared responsibility provisions, even if separately the employer would not be an ALE.

 

 

We transferred to Avionté this year from a different software, what do we need to do to ensure proper reporting?
Avionté will need to determine what data was converted from your old software provider. Please create an Avionté Support Center ticket explaining your situation.

 

 

Are clients charged for assistance with the entire ACA process set up in Avionté?
There may be charges associated with this type of in-depth support. For a better idea of pricing, please create an Avionté Support Center ticket describing your needs.

 

 

Even if we are not an ALE in 2015, but are offering a 100% Employer paid MEC plan, should we still be setting up the contributions? We won't have to report 1094-C or 1095-C forms in 2016, correct?
Contributions should still be setup. You will not be required to file this year, but may be subject to that for next year’s filings. Your reporting requirements for 2015 depend on if your plan was fully insured or self-insured. If you're a non-ALE offering self-funded MEC, you should provide 1095-B to all covered employees.

 

 

Employee is paying all of the plan, do I still need to enter an employer contribution of $0?
If the employee is paying all of the plan, you only need to enter the employee’s deduction.

 

 

In the AC Census AQ, what should be entered to gather all of the information necessary for a given year?
The start date should come before the beginning of the desired year and the end date should be in the following year (expanding the work week over the year end).


2015 Example
Start date: 12/29/14
End date: 1/03/16

 

 


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