People-Trak and the ACA and the ACA.pdf · “C” Series Forms: The 1094C and 1095C forms are used for employees who have employer provided medical health benefits. Because the employer

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People-Trak and the ACA

Contents

1 – Definitions 2

2 – Frequently Asked Questions 4

3 – Plan Types 6

4 – Plan Type Use within the Benefits Administration Module 7

5 – Plan Type Use within the Personnel Module – Current Enrollment 10

6 – Plan Type Use within the Personnel Module – Prior Participation 15

7 – Plan Type Use within the Personnel Module – Prior Participation 17

8 – ACA Manager 18

9 – ACA Reports and Forms 24

Disclaimer: This is a document produced before the final changes to People-Trak and before

the final documents produced by the IRS. Some changes will be made and should be

expected. However, the basically functionality as described herein should be essentially the

same.

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1 – Definitions

Insurance Carrier: The organization responsible for providing benefits to your employees.

There is always a carrier. If your insurance is provided by a third party such as Blue Cross, then

Blue Cross is the carrier. If you self-insure your employees, you are the carrier. The ACA

places the responsibility for providing the 1094 and 1095 forms on the carrier: which would be

the third party carrier or you. If you have some employees with coverage provided by a third

party carrier and some with coverage provided by self-insurance, the forms will be provided by

the respective carrier in each instance.

Employer Sponsored Coverage: Coverage where the employer provides medical health

benefits through a third-party carrier. The carrier is responsible for the IRS reporting using the

“B” series of forms described below.

Employer Provided Coverage: Coverage where the employer self-insures medical health

benefits. There is no third-party carrier. The employer is essentially the carrier and is thus

responsible for IRS reporting using the “C” series of forms described below.

“B” Series Forms: The 1094B and 1095B forms are used for employees who have employer

sponsored benefits. The 1094B and 1095B forms will be provided by your insurance carriers.

The “B” series of forms can be produced within People-Trak, but this would be for memo

purposes as the carrier is obligated to provide these.

“C” Series Forms: The 1094C and 1095C forms are used for employees who have employer

provided medical health benefits. Because the employer is the “carrier”, the employer is

responsible for producing the 1094C and 1095C. The “C” series of forms can be produced

within People-Trak.

1094 Statement: The 1094 (B or C) is a statement that must be provided to the employee much

like a payroll W-2 that details the coverage they have been provided. The 1094 statements for

all employees are also provided to the IRS.

1095 Transmittal: The 1095 (B or C) is a transmittal cover sheet that is sent to the IRS with the

stack of 1094 (B or C) statements that have been produced for the employees.

Electronic Filing: For employers with 250 or more 1094-B or 250 or more 1094-C forms, the

IRS requires that a file be uploaded electronically in lieu of a paper forms. The file format is

dictated by the IRS and includes an electronic equivalent of the 1094 statements and the 1095

transmittal. People-Trak will produce the file to the IRS format for both the “B” series and the

“C” series, but will not be responsible for the upload.

Per Enrollee: A costing method where the total cost for the benefit plan is determined by the

sum of the insurance for each enrollee. Each enrollee is priced separately based on age and

other demographics and the total is determined when enrollment is complete. There is no

defined cost as there is with a group plan using “per group” costing. With the ACA, all benefits

are defined “per enrollee” and the coverage is the sum of the cost for each enrollee.

Per Group: A costing method where the total cost for the benefit plan is determined by the

group and not the sum of the cost for each individual enrollee. An employee or family normally

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falls into a group based on family size and demographics. Traditionally most health insurance

has been priced using this methodology.

Benefit Program: A primary category of benefits such as medical, dental, vision, life, etc. In

People-Trak, you can define as many programs as you wish. All true medical programs fall

under the ACA. Other programs do not. People-Trak is not limited by program. You can have

multiple programs that offer ACA plans and they do not need to be named “medical”. For

complete flexibility, you can decide program names and what plans are offered within a given

program. It is possible to offer both ACA and non-ACA plans within a program.

Benefit Plan: A sub-category of a benefit program. You may have more than one plan within a

program. For example, in a non-ACA program, you might multiple group plans from one or

more carriers. Within an ACA program, you might have different plans from different carriers.

Plans in People-Trak are not limited by the ACA. You can offer both ACA and non-ACA plans

within a program if it is necessary to do so.

Benefit Rate: A rate within a plan. Most plans have different rates depending on age, gender,

smoking habits or other demographics. Within a group plan, the employee normally determines

the group rate and the group rate applies to the group. Within an ACA or per enrollee plan,

there is a rate for each age bracket and the total rate is determined as the sum of the individual

rates for each enrollee.

Part-Time Eligibility for Benefits: The ACA states that all employees who work 30 hours or

more per week are eligible for benefits “as with any other employee working full time”. That part

makes sense. It gets somewhat more confusing when determining how to calculate the 30

hours per week. The ACA provides a set of guidelines to set a company policy in this regard

and to protect both employer and employee from confusion.

In general, using the ACA guidelines, the employer sets a period for new hires during which the

hours worked are tracked. At the end of that period, the hours are checked and if the 30 hour

minimum is met, the employee is deemed eligible. Likewise, using the ACA guidelines, the

employer sets a frequency and a period during which hours are checked to determine

continuing eligibility.

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2 - Frequently Asked Questions

1. Who is responsible for providing the ACA documents?

The carrier is responsible for providing the ACA documents. If you have a third-party carrier,

that carrier will provide the statements. These are known as the “b” series. If you are self-

insured, you are the carrier and you will provide the statements. These are known as the “c”

series.

2. How is People-Trak addressing the ACA?

All of the changes to support ACA have been made in version 9.1. Many of the changes were

made and demonstrated in early 2015. However, the ACA really only became “stable” in June

when the final challenge was overturned in the Supreme Court. Since that time, we have been

making final adjustments and programming the forms and statements… which are a moving

target because the IRS is still working on them.

3. Will People-Trak produce the statements?

Yes. People-Trak can produce produce the 1094 statements and the 1095 transmittal for both

the “b” and the “c” series. Remember, however, that the “b” series will be provided by your

third-party carrier.

4. What do we have to do to be ready?

All ACA plans are “per enrollee”. That means that you need to modify your current enrollment to

reflect the per enrollee basis. People-Trak version 9.1 will provide the changes to support “per

enrollee” enrollment.

5. When will version 9.1 be ready?

We will begin installing version 9.1 soon after November 1. A conversion of your data will be

required from any previous version including 7 series, 8 series, and 9.0 series. Once the

product has been installed and your data converted, you may begin adjusting enrollment as

necessary. Please remember that if you have a third-party carrier, that carrier will be providing

all relevant forms for you. If you are in ACA compliant medical enrollment for 2015, your carrier

will already have the data for “per enrollee” ACA costing. It would not be necessary to have

People-Trak fully set this year because the carrier is providing the statements..

6. When are the forms due?

This is a moving target. Normally, and 2015 is NOT a normal year, the forms would be provided

as part of the W-2 process. After all, these forms are going to the IRS, not some ACA

organization. (Yes, this is about taxes). For 2015, the government is more concerned about

employers and carriers knowing how to do this then getting it exactly right or on time. The most

recent information we have seen indicates that the 1/31/2016 deadline for W-2 forms will not be

applicable for the ACA forms. The ACA forms can be provided as late as 3/31/2016. If you are

a self-insured company, you may wish to check the IRS publications for the latest information.

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7. Will the People-Trak forms be compliant?

We are using the PDF forms provided by the IRS. The PDF forms are used as a background

image and we then place the relevant data on the forms. If the IRS is compliant, our forms are

compliant. The fact the IRS forms still state “Draft” is indicative.

8. Are the carriers ready?

Due to legal challenges to the ACA (that were only resolved in June), most carriers and

software providers and the IRS are behind. We are covered by the Anthem, which is a Blue

Cross organization in California (one of the largest in the world). When we asked when we

would receive our 1094 “b” forms, they could not provide a meaningful answer.

9. Will there be penalties for the 2015 year?

In our opinion, this is unlikely as even the IRS is not ready for 2015. Online copies of the forms

are still stamped with “Draft” which indicates IRS readiness for this process. Also, various due

dates for the forms have changed. It would appear that 2015 is going to be graded on effort and

not achievement. As always, it will be important to meet the dates and to provide reasonable

information as requested. Again, check with IRS publications, especially if you are self-insured

and are responsible for the forms.

10. What is the minimum employee count for electronic reporting?

At 250 employees in either the carrier provided category or the employer provided category, you

are required to file electronically. If you have a mix of carrier provided and employer provided

coverage, each category is counted separately. If you have 280 employees and 249 are

covered by a third party carrier, you do not file electronically.

11. Will People-Trak produce the necessary electronic reporting file?

Yes, there is a complex specification provided by the IRS. As that specification becomes file,

we will produce the file from the data in People-Trak. Again, this only matters for self-insured

companies as the third party carrier is responsible in other cases.

12. Will People-Trak transmit the file to the IRS?

No. As with other compliance documents, People-Trak produces the documents or files and the

user is responsible to get that document or file to the appropriate agency. There are also

security issues regarding the transmission process which are best met by the employer. The

specifications for the transmission are beyond complex to understand. If you will be required to

transmit electronically, we strongly suggest you start work now, or select some type of

supporting company that will no doubt be popping up.

13. Will People-Trak assist with determining Part-Time Eligibility?

Yes. Normally, you would define an “Hours Worked” account within the attendance features.

Then, within each period, you would key batch in the hours actually worked by the employee.

With settings made in the Setup screen, we can determine if a new employee is eligible over the

introductory eligibility period. Subsequently, using the accumulated data, we can determine

continuing eligibility using the settings you have made.

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3 – People-Trak Plan Types

A very important new field has been added to define and clarify the use of benefit plans within a

benefit program. The plan type codes can be used for all plans within all programs. However,

ACA plan type codes are generally only used for qualifying medical programs.

ACA: This code is used for an ACA plan for Employer Sponsored Coverage. Rates are defined

on a per enrollee basis. This code only applies to medical programs. It should not be used with

dental, vision, or other programs. If you wish to use per enrollee pricing with non-ACA

programs, use the “Enroll” code.

ACA-SG: This code is used for an ACA plan for Employer Provided Coverage with rates defined

on a per group basis. Because employers who self-insure can define coverage by groups or

per enrollee, this code can be used as necessary. This code only applies to medical programs.

It should not be used with dental, vision, or other programs. If you wish to use group pricing

with non-ACA programs, use the “Group” program.

ACA-SE: This code is used for an ACA plan for Employer Provided Coverage with rates defined

on a per enrollee basis. Because employers who self-insure can define coverage by group or

per enrollee, this code can be used as necessary. This code only applies to medical programs.

It should not be used with dental, vision, or other programs. If you wish to use per enrollee

pricing with non-ACA programs, use the “Enroll” program.

Group: This code is used for non-medical programs for Employer Sponsored Coverage with

rates defined on a per group basis.

Enroll: This code is used for non-medical programs for Employer Sponsored Coverage with

rates defined on a per enrollee basis. With the advent of per enrollee pricing driven by the ACA,

it is assumed that per enrollee pricing may propagate to other benefit program types. This code

has been provided to prepare for that.

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4 - Plan Type Use within the Benefits Administration Module

The new plan type code is used within the Benefits Administration module to determine which

rate methodology supporting screen is to be displayed. The code is used on both the Current

and Future plans screens. A sample screen with the new Plan Type column is shown below.

The screen that is displayed when you use the “Rates:1” button is determined by the plan type.

There is a different screen for “group” plans and “per enrollee” plans. In planning for the future,

People-Trak has allowed for “per enrollee” plans for non-ACA programs. As the carriers find the

benefits from “per enrollee” costing, we expect that other non-ACA programs such as dental will

require this methodology.

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4.1 - Group Plan Types

When the Plan Type is set to ACA-SG, or Group, the “per group” rate screen is displayed. This

screen is used to define a group on each line. The age bracket and smoker status apply to the

employee who defines the group. Group plans support fixed, data entry, and computed

premium types. Once the premium type has been set, the appropriate screen is displayed when

the Details button is used.

Group plans are not nearly as specific as “per enrollee” and various carriers have different

designations for groups. The “per enrollee” method is far more precise, and unfortunately more

expensive.

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4.2 - Per Enrollee Plan Types

When the Plan Type is set to ACA, ACA-SE, or Enroll, the “per enrollee” rate screen is

displayed. This screen is used to define the rates for each age/demographic category within the

plane. The individual lines do not constitute the total cost for a given employee, but rather the

individual costs for potential members. When enrollment is completed for an employee, the rate

for each enrolled member is totaled to create the total premium for all covered members. A

sample is shown below.

Because it can be tedious to define the age brackets for multiple plans, you can use the Copy

Rates button to copy the age brackets from one plan to another.

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5 – Plan Type Use in the Personnel Module – Current Enrollment

When a program/plan combination is selected within the Personnel module, the plan type

specified within the plan is brought into the screen shown below. The plan type cannot be

modified within the Personnel module because it is part of the program/plan defined within the

Benefits Administration module.

The plan type is used to determine which enrollment screen should be displayed what settings

apply to that screen.

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5.1 - Group Plan Types

When the Plan Type is set to ACA-SG, or Group and Details button is pressed, the “per group”

enrollment screen is displayed. This screen is used to specify the members of the group, but

the plan cost is not determined by the members of the group. The plan cost was determined by

the plan when it was created in the Benefits module.

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5.2 - Per Enrollee Plan Types

When the Plan Type is set to ACA, ACA-SE, or Enroll, the “per enrollee” rate screen is

displayed. This screen is used to enroll each member of the group and to calculate the total

premium cost. The screen differs slightly for each of the three “per enrollee types”. A sample

screen for the “ACA-SE” type is shown below.

5.3 - Member Enrollment History

For all of the “per enrollee” types, the History button is shown to the right of the grid. This is

used to display and archive prior enrollment in the current year for the member. A sample of

this screen is shown below.

The Archive button is used to move the enrollment to the right and to clear the Current entries.

When the screen is closed, the Enrolled, Effective Date, and Expiration Date fields are cleared

on the grid for the selected member so that new entries are made. When modifying member

enrollment during a given year for ACA plans, it is important to use the history button (do not

change the fields) so that the ACA detail generation can identify gaps in coverage. The Clear

button is used to clear the history completely.

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5.4 - ACA Member Enrollment Details

For both the “ACA” and the “ACA-SE” plan types, the ACA button is shown to the right of the

grid. This is used to display the ACA enrollment details that are used on the 1094-B and 1094-C

statements. A sample is shown below.

This screen is normally populated during the ACA generation process. The current enrollment

and historical enrollment are used to determine the months during an employee or dependent is

actually covered. The Load button can be used to process an individual member in the same

way that the entire company is processed during the generation process. The Load button can

be used for testing purposes or to reprocess after an error has been corrected. For example: if

after the generation process, the validation process determines that there is an error, you can

correct the enrollment error within an employee record. You can then either reprocess the

entire company or simply use the Load button for one or more enrolled members. This is much

faster.

Per ACA guidelines, if an employee had coverage for the entire year, only the first box will be

checked. If there are gaps in the coverage, the individual covered months will be checked. The

checkboxes correspond to matching fields on the 1094-B and 1094-C statements.

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5.5 - ACA 1095-C Coverage Details

For an “ACA-SE” plan type, the ACA Coverage button is included to the right of the upper

frame. This used to display the 1095-C Coverage Details screen. A sample is shown below.

This screen is used to record the coverage offer details that are unique to the 1095-C

statement. The fields correspond to matching fields on the 1094-C statement.

We have not yet determined how the coverage details can be determined and automatically

generated. We are still working on this process by combing through IRS documentation. If we

are not able to generate this detail, you will be required to key it, import it, or otherwise use

Database Manager to generate it.

5.6 – Simple “Per Enrollee” Screen

For a non-ACA “Enroll” plan type, the ACA Coverage button and the “ACA” button are not

relevant and are not displayed. Please note that “per enrollee” enrollment for non ACA plans

has been provided because it is assumed that carriers are going to begin using this costing

method for other types of plans. If this does not come to pass, you will not need to use non-

ACA per enrollee codes.

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6 - Plan Type Use within the Personnel Module – Prior Participation

When a program is archived for an employee, it is moved from the Current Enrollment screen to

the Prior Participation screen shown below.

6.1 - Group Plan Types

When the Plan Type is set to ACA-SG, or Group and the Details button is pressed, the “per

group” enrollment history screen is displayed as shown below. This screen details the

enrollment in the group plan at the moment the plan was archived. Because history is

continuous, there is no totaling of costs based on enrollment.

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6.2 – Per Enrollee Types

When the Plan Type is set to ACA, ACA-SI, or Enroll and the Details button is pressed, the “per

enrollee” enrollment history screen is displayed as shown below. This screen details the

enrollment in the group plan at the moment the plan was archived. Because history is

continuous, there is no totaling of costs based on enrollment.

6.3 - Member Enrollment History

For all of the “per enrollee” types, the History button is shown to the right of the grid. This is

used to display prior enrollment in the current year for the member. A sample of this screen is

shown below.

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7 - Plan Type Use within the Personnel Module – Future Enrollment

The future enrollment screens are very similar to the current enrollment screens with the

following exceptions.

There is no ACA detail for any of the plan types as this detail is never recorded in

advance. Thus, the “per enrollee” screens do not have the Detail button.

There is no ACA coverage detail for the primary individual for the self-insurance plan

types since this detail is never recorded in advance. Thus, the “per enrollee” screens do

not have the ACA Coverage button.

There is no enrollment history from future years and thus the “per enrollee” screens do

not have the History button.

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8 - ACA Manager

The ACA Manager program is provided in the Benefits Administration module. It is used to

guide and assist in the processing of ACA reporting. The ACA Manager uses a multi-tabbed

screen. A sample of the first tab is shown below.

This tab provides a summary of the work processed to date. As steps are completed on

subsequent tabs, the event is checked and the date is set to the most recent date the task was

performed. This tab and subsequent tabs are split into two sections: the top section is for

Employee Sponsored Coverage (there is a carrier) and the Employee Provided Coverage (the

company is the carrier). Most employers will use one of the two sections. However, in some

instances, larger employers with multiple companies may offer both sponsored and provided

coverage. In this instance, each section must be processed.

When the ACA Manager is launched, a query determines the number of employee records for

each of the two types. The value is displayed in the first field in each section. If the number of

records is less than 250, a message indicating that electronic filing is not required is displayed.

If there are 250 or more records, the message indicates that electronic filing is required. When

we get to the transmittal page, the message is echoed and the Create File button is enabled as

necessary.

The Clear buttons are used to clear the data from the prior year or from any test process. Each

step in the process can be run more than once. The dates indicate the most recent time the

process was run.

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8.1 - ACA Manager – Clear Tab

This tab is used to clear or initialize the settings in employee and dependent records to prepare

for the current year processing. For Employer Sponsored Coverage, the 13 checkboxes

indicating the covered months are all cleared. For Employee Provided Coverage, the 13

checkboxes indicating the covered months are all cleared and the ACA 1094-C statement fields

are also cleared.

When the Clear Coverage Details buttons are used, the process begins. When the process is

complete, the message adjacent to the button is updated to reflect the actual number of records

cleared.

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8.2 - ACA Manager – Update Tab

For both types of coverage, this tab is used to compute the monthly enrollment and to update it

to the respective employee and dependent records. The process will check programs that have

been archived during the current year as well as any member coverage that has been archived

during the current year. The end result will be the series of checkboxes described above.

These checkboxes then serve as the primary detail for the 1095-B and 1095-C statements.

For provided coverage, the process attempts to determine 1094-C offer details.

When the Update Coverage Details buttons are used, the process begins. When the process is

complete, the message adjacent to the button is updated to reflect the actual number of records

updated.

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8.3 - ACA Manager – Validate Tab

This tab is used to generate standard reports that show the details that have been created by

the Update process. Using the reports and the provided screens, you can verify that the

statements are ready to produce.

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8.4 - ACA Manager – Statements Tab

This tab is used to print the statements for manual distribution to either the employees or to the

IRS.

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8.5 - ACA Manager – Transmittal Tab

This tab is used to print the 1095 transmittal document for the IRS. If you are a qualifying

employer, this tab can be used to produce the electronic file necessary for IRS submission.

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9 – ACA Reports and Forms

Through a combination of reporting features, the following documents will be provided. In

addition, with the Adhoc Reports tool and the Forms tool, you can create a wide variety of other

reports as needed.

1094 and 1095 Standard Reports

The following statements and transmittals will be provided as standard reports. The reports will

be created using the IRS provided PDF’s for the layout and People-Trak form technology to

place the data. The same reports will be available from the Standard Reports document

manager so that you can use a query to limit or expand the number of employees to be

included. This is useful if you just need to produce a single corrected statement or to reprint the

transmittal after other data entry has been corrected.

1094 “b” Statement

1094 “c” Statement

1095 “b” Transmittal

1095 “c” Transmittal

1094 Data Validation Standard Reports

The following reports will be provided as standard reports that would be normally produced from

within the ACA Manager. The same reports will be available from the Standard Reports

document manager so that you can use a query to limit or expand the number of employees to

be included.

1094 “b” Data Validation Report

1094 “c” Data Validation Report