Health Care Reform Reporting requirements (ACA)

[jwiblepasshe22]

As an update, we (PASSHE) just had a call with the SAP Product Manager on the IRS requirements to deliver reports for IRS sections 6055 and 6056. At this point, SAP says that custom reports/forms would need to developed to meet these requirements. Based on our understanding of these requirements, specifically for forms 1095-C and 1094-C described below, these requirements will be very time consuming and costly for companies to address with custom reports and forms. However, if your company has already developed specifications for the development of these reports/forms, please respond to this forum. Likewise, if you do not have customization plans and feel these requirements should be addressed by a standard SAP solution like W2's, COBRA, New Hire Reporting etc., please provide your response as well.

Thanks,

Jeff Wible

ASUG HCM Community Facilitator

Director, SAP Human Capital Management Systems

Shared Administrative Systems

Pennsylvania State System of Higher Education

jwible@passhe.edu

ACA Documentation Requirement Summary

Source: IRS.GOV. Bulletin – March 24, 2014 – T.D. 9661

Employee Statement Section 6056

1. Required for all full-time employees (30 hours per week)
2. Employee document can be furnished electronically if consent is modeled after the W2 process
3. Must be delivered by January 31^st of the following year
4. Data required (form 1095-C)
   1. ER name, address, and EIN
   2. ER contact and phone number
   3. EE name, address, and SSN
   4. Same information listed on the employer statement relevant to the employee (d to h below)

Employer Statement Section 6056 (section 6055 self-insured) can be combined form

1. Due by February 28 if paper, by March 31 is filed electronically
2. Date required (form 1094-C)
   1. ER name, address, and EIN
   2. ER contact and phone number
   3. Date the return is filed
   4. Minimum essential coverage meeting minimum value was offered
      1. the employee only;
      2. the employee and the employee’s dependents only
      3. the employee and the employee’s spouse only
      4. the employee, the employee’s spouse and dependents
   5. Coverage was not offered to the employee and:
      1. any failure to offer coverage will not result in a payment under section 4980H(a) or (b), for example because the employee was in a limited non-assessment period for certain employees, as defined in § 54.4980H–1(a)(26);
      2. the employee was not a full-time employee;
      3. the employee was not employed by the ALE member during that month
      4. no other code or exception applies;
   6. Coverage was offered to the employee for the month although the employee was not a full-time employee for that month
   7. The employee was covered under the plan
   8. The ALE member met one of the affordability safe harbors under § 54.4980H–5(e)(2) with respect to the employee.

[nomad]

Jeff/All,

Just FYI I added this comment over at the main thread now - as it seems most are still looking here for answers too.

So it seems that apply the notes early is causing issues/incomplete.

When will ALL the ACA notes/forms/documents/features be included in Support Packs?

In the previous thread it was mentioned September 10th is this still the case?

Should most wait until the WebCast on the 17th or is that not technical/install related?

Hope they respond ASAP....

-Chris

[jwiblepasshe22]

Chris,

This is what I received directly from SAP as far as their immediate plans for the ACA functionality:

Additional information:

For the most up-to-date information on SAP ERP HCM US Benefits Management, please see http://service.sap.com/hrusa: SAP Note 2060131 has been updated with the numbers of the SAP Notes that deliver the functionality for Information Reporting for Employer Sponsored Coverage and Minimum Essential Coverage. Please refer to the References section of the Note.

ASUG Webcast: Affordable Healthcare Act (ACA) - Review of SAP’s solution for Information Reporting for Employer Sponsored Coverage and Minimum Essential Coverage Requirements is currently scheduled for Thursday, September 17, 2015 10am PST (please register via ASUG event page)

Roadmap: Due to the recent release of IRS publication 5165 Guide for Electronically Filing Affordable Care Act (ACA) Information Returns (AIR) for Software Developers and Transmitters on August 18, 2015 and the pending release of the final 1094 and 1095 forms and instructions for 2015,

SAP is planning the following delivery schedule to address upcoming legal changes and corrections for Information Reporting for Employer Sponsored Coverage and Minimum Essential Coverage:

General Availability            SAP note 2167502            Released on August 28 o 1st SAP ACA Note Update

SAP Note 2211233           Planned for week of September 21, 2015 o 2nd SAP ACA Note Update

SAP Note 2211234           Planned for week of October 12, 2015 o 3rd SAP ACA Note Update

SAP Note 2211235           Planned for week of November 16, 2015 o Electronic Filing SAP ACA Update

SAP Note 2211236           Scheduled for December 2015 CLC, planned to be available on December 10, 2015