How to Prepare for the Next Act of the Affordable Care Act (ACA)
Dwayne Brucke, Principal Consultant, HCM Infor LOB has been working with the Infor products for over 10 years. His primary focus is Human Capital Management with a focus on Talent Management.
The next components of the Affordable Care Act (ACA) are fast approaching and Velocity Technology Solutions would like for you to know what we are doing to prepare ourselves and you, our customers, for these components.
In March 2014 the IRS published its final Treasury Regulations that involve both employers and employees. For employers, IRC Section 4980H details the responsibilities of employers in Health Care Provisions. In this regulation, it addresses Applicable Large Employers (ALE), form 1094C, and form 1095C.
Presently, Infor is in the final development stages of modifying programming to be in regulatory compliance with the Internal Revenue Code (IRC). They have developed 6 new processes and have modified at least 20 existing programs to handle the ACA requirements. Through communication with Infor, beta testing of the programs, modifications and application updates has begun. There will be new forms for processing ACA and intend to have these become generally available late summer. One of our customers is participating in the ACA Beta testing program, which will provide us additional insight to the new functionality and programs.
Our Velocity team has been proactive in leading the ACA initiative internally, by meeting regularly to prepare for the roll out of the new functionality, as soon as the updates are delivered from Infor.
What can you do to prepare your organization? Velocity Technology Solutions and Infor recommend the following tasks that can be done now, while the final development is being tested:
- Create a new pay class, i.e. ACA which will house your hours used in calculating hours of service for full time determination (average 30 hours/week or 130 hours/month)
- Classify positions as seasonal, variable-hour, part time or full time
- Determine Measurement Assessment Periods
- Review Health Coverage Options - Waive Plans (must have them)
- Review Employee Groups - Verify you are using Employee groups for enrollment in and out of plans
- Review and update Dependent information - Dependents must have a social security number or date of birth (preferably both)
In addition, you must review and categorize health plans (new BN15 options):
- Self-insured or fully-insured
- Best offer plans
- Safe Harbor Code
To help with your readiness for the new programs, Velocity is offering an introductory 4-hour functional application discovery to review existing benefit configuration, with the intent to recommend updates and/or configuration changes due to the new ACA requirements.
This is a basic discovery consulting offering and is not intended to include assistance making recommended configuration changes. We can provide an estimate for further consulting services as a result of the ACA discovery consultation.
The discovery includes:
Delivery and running of a Dependent's Query. This is used to verify that all dependents are setup correctly.
Review of existing Waive plans
Review of existing Position Control, if used
Written recommendations based on review
For more information on this offering, please contact your Customer Program Manager or contact us here.
If you would like further information on ACA and what Infor is doing to address these new regulations, here are some helpful links:
1094-C - Transmittal of Employer Provided Health Care Coverage (form and instructions)
1095-C – Employer-Provided Health Insurance Offer and Coverage Insurance (form and instructions)
For the final regulations under section 4980H, Shared Responsibility for Employers Regarding Health Coverage, see T.D. 9655, 2014-9 I.R.B. 541
As more information becomes available to Velocity Technology Solutions, we will keep our internal resources and our customers abreast of these updates, but if you have any questions, please feel free to contact us at any time.