Affordable Care Act (ACA) Reporting in Oracle E-Business Suite

Robyn Davidson, HR Business Analyst

rdavidson@hrsd.com

May 3, 2019

• Purpose: – To determine if employer sponsored health plan(s)

which provide minimum essential coverage are offered to all full-time* employees

– Whether the offered health coverage qualifies as affordable under the ACA

* Who is considered full-time for ACA?

Full-time = worked average of 30+ hours/week for more than 120 days in a year

ACA Reporting Basics

2

• Form 1094-B*, Transmittal of Health Coverage Information Returns

• Form 1095-B*, Health Coverage *1094-B & 1095-B not supported by EBS • Form 1094-C, Transmittal of Employer-Provided Health

Insurance Offer and Coverage Information Returns • Form 1095-C, Employer-Provided Health Insurance Offer and

Coverage

• 250+ returns must file electronically

ACA Reporting Basics

3

• New electronic filers: Refer to IRS Tax Topic Number 802 - Applying to File Information Returns Electronically 1. Apply for Transmitter Control Code (TCC) more

than 45 days before filing deadline Two Responsible Officials

2. Pass communications test

ACA Filer Setup with IRS

4

5

Setup in E-Business Suite

• Use system setup guide: – Oracle Advanced and Standard Benefits

Affordable Care Act Employer Reporting Setup Guide (Doc ID 2188907.1)

Includes screenshots of the necessary configuration of the GRE, benefit plans, etc.

• Setup life events to detect when EE’s are

ACA full-time eligible and ineligible, based on hours worked

ACA Setup in EBS – One-time Setup

6

• Annual configuration – Add reporting year to health plan(s) Total Compensation > Programs and Plans > Plans > Extra Information

ACA Setup in EBS – Annual Basis

7

• Ongoing configuration – ACA Full Time flag for all new ACA full-time

employees

ACA Setup in EBS – Ongoing Basis

8

• Who to designate as ACA full-time? – Use System Extract tool to view employee payroll

balance data/hours worked Using System Extract to View Eligible Employee Service Hours (Doc ID 1990141.1)

– Review the ACA full-time eligible and ineligible life events to document offers to EE’s to process events

ACA Setup in EBS – Ongoing Basis

9

• One GRE • Active employees pay no coverage premium • HRSD employee population

900-1000 total active employees - No partial year EE designations (ex: 10 month) < 50 Part-time employees <100 Retirees/dependents

To avoid tracking of hours HRSD changed business rule so all non-seasonal part-time employees are offered health benefits

HRSD Organization Setup

10

• COBRA recipients managed outside of EBS can be documented for reporting

• HRSD has not yet had any COBRA enrollments

ACA Setup in EBS – Ongoing Basis

11

12

Creation of the 1094-C and 1095-C

• Current ACA concurrent processes: – Benefits ACA Archive Process – Benefits ACA Purge Process – Benefits ACA 1095C Print Report – Benefits ACA Persons Report for 1095C Printed

Forms *NEW for 2018 reporting year

– Benefits ACA Transmission XML Generation Process

– Benefits ACA process Error Data XML – Benefits ACA Errors Report – Benefits ACA Correction Archive Process

ACA Concurrent Processes

13

• Per GRE, run the Benefits ACA Archive

Process to create 1094C and 1095C data. – Review 1095C’s at US Super HRMS Manager > ACA >

View Employee Archive Data – Review 1094C at US Super HRMS Manager > ACA > View

Authoritative 1094C

• After making corrections run Benefits ACA Purge Process and rerun the Archive process 1094C/1095C forms

HRSD Step 1. Create the Archive & Review

14

Benefits ACA Archive Process

Benefits ACA Purge Process

• Benefits ACA 1095C Print Report produces a

PDF or XML output of employee 1095C forms • Benefits ACA Transmission XML Generation

Process – Note: cannot create XML transmission file until

Oracle ACA Phase II patch is applied

HRSD Step 2. Create the 1095C forms and/or XML data for audit

15

Benefits ACA Archive Process

Benefits ACA 1095C Print Report

Benefits ACA Transmission XML Generation Process

• After creation of the XML transmission file, to display any updates/corrections made to EE records, the Purge process must be run twice – Purge the XML first – Purge the archive second

• Rerun the Archive process

HRSD Step 2. Create the 1095C forms and/or XML data for auudit (cont.)

16

Benefits ACA Archive Process

Benefits ACA Transmission XML Generation Process

Benefits ACA Purge Process

1

2

• Break population into categories and identify which/how much of each group to audit, based on most and least likely to have errors

• Our categories for review: – 100% audit

New hires Terminations Retirees Part-time EE’s EE’s with >= 5 dependents Dependents with no SSN (or 000-00-0000)

HRSD Step 3. Review & Audit 1095C form data

17

• We compare monthly coverage data received from our health insurance provider to the monthly indicators in the XML output – Technical notes: the XML output provided by the Benefits

ACA 1095C Print Report has masked SSN – The Benefits ACA Transmission XML Generation Process

has the full SSN and is better for use in the audit, but cannot be created until after ACA Phase II patch is applied

• Review each discrepancy – Comparing to medical provider reports may be HRSD

specific as we have not had electronic interface from EBS to medical provider

– We have an interface as of July 2018 so will have far fewer discrepancies going forward

HRSD Step 3. Review & Audit 1095C form data (cont.)

18

• Note that your particular benefit plan setup will impact the codes that appear in Part II, boxes 14, 15, and 16 – For example, dependent designation requirements can result

in employees having different box 14 codes, depending on whether they have eligible dependents

– At HRSD we see two scenarios, regardless of dependent coverage: EE’s with eligible dependents will have 1A in box 14 EE’s with no eligible dependents will have 1B in box 14

HRSD Step 3. Review & Audit 1095C form data (cont.)

19

• New for 2018 filing year – Oracle rolled out electronic 1095C consent/view for employee self service – EE can consent to electronic statement – “Benefits ACA Persons Report for 1095C Printed Forms” produces

list of EE’s who did not consent, for printing fewer paper forms * However, employee cannot produce an actual 1095C form style output to print/save with taxes, so HRSD did not rollout the 1095C consent screen in self service this year

HRSD Step 4. Distribute 1095C to Employees

20

• Print report (PDF) gives option for both laser cut and self mailer

forms • Note that self mailer does not include a return mailing address

field so we add this by creating a custom form template – Go to XML Publisher Administrator > Home > Templates – Search for “Benefits ACA%” and select applicable reporting year – Download seeded template and add return address text (using

Adobe Acrobat Pro) – Note that the PDF file version must be 1.4, so in Acrobat Pro go to

File > Save as Other > Reduced Size PDF and make compatible with Acrobat 5.0 and later

– Save the PDF file as a different name

HRSD Step 4. Distribute 1095C to Employees (cont.)

21

Benefits ACA 1095C Print Report

• (cont. creating custom 1095C template) – Create a new template by duplicating the seeded one – select the

seeded template and click Duplicate icon – Enter a new Code and Name for this template. This name is what

will display as the parameter when running the ACA Print Report – Update the template to use the PDF you just created, and save – Your new template will now appear as a parameter

HRSD Step 4. Distribute 1095C to Employees (cont.)

22

• We mail forms to employees prior to the IRS deadline • Give EE’s two weeks to report back errors/issues and

then we submit the electronic file

HRSD Step 4. Distribute 1095C to Employees (cont.)

23

• This process creates two files – the manifest and the

transmission file, both must be submitted to IRS • This is the output:

• New in 2018 reporting year the process also allows you to designate an output directory other than default /usr/tmp

• A Responsible Official must perform the submission steps on the Affordable Care Act Information Returns (AIR) production site – https://la.www4.irs.gov/airp/aca/ui/

HRSD Step 5. Electronic Submission to IRS

24

Benefits ACA Transmission XML Generation Process

• After submission be sure to save your Receipt ID (screenshot). • Processing times vary on the website and the result can take a

considerable amount of time Rejections come back quickly in our experience

• Once processed, any status other than Accepted will generate an “Ack” XML file with the error data – Transmission results:

HRSD Step 5. Electronic Submission to IRS (cont.)

25

• With your Receipt ID (and error file if not Accepted) go to US Super HRMS Manager > ACA > ACA Transmission Details

• Update and enter the Receipt ID and upload Ack error file; Apply

HRSD Step 6. Update Transmission Status

26

• After the “Ack” errors file has been uploaded run the Benefits ACA process Error Data XML process. Once complete run the Benefit ACA Errors Report.

• Review the Errors report, which will indicate the employee record with the error – Error Text gives information on the type of error

Most HRSD errors are dependent SSN/name mismatches – Xpath column tells you which covered individual record is in

error, but not the person name Refer to the XML Transmission file > applicable Employee record >

then after the “<CoveredIndividualInd>1</CoveredIndividualInd>” tags count to the affected person record

HRSD Step 7. Process Errors and Review

27

Benefits ACA process Error Data XML

Benefits ACA Errors Report

• Example: the 3rd covered individual record for Jane Doe has the SSN/name mismatch

HRSD Step 7. Process Errors and Review (cont.)

28

• Review all of the errors and make corrections • Note that if in “Accepted with Errors” status you have

at least met the IRS filing deadline due date. Corrections to bring to Accepted status should be submitted “as soon as possible”

• HRSD errors received and resolutions: – Dependent Name/SSN mismatch - dependents may be

reported with Date of Birth instead We remove the SSN’s for affected dependents which sends

with the name and DOB – Employee Name/SSN mismatch

This has always been caused by compound or hyphenated last names; these must be corrected, cannot send EE with just DOB

HRSD Step 7. Process Errors and Review (cont.)

29

• If you identify any errors on your own, you can mark previously accepted employee records in error. This will include them in the subsequent correction XML transmission file

• Go to US Super HRMS Manager > ACA > View Employee Archive Data > query employee > Mark Error button

HRSD Step 7. Process Errors and Review (cont.)

30

• Note that once the transmission status is updated,

until you generate a new Transmission XML, you can not run the ACA Purge Process, or the Archive Process – Ex: Authoritative GRE ID: 81 is already transmitted to the

IRS, cannot run Purge Process(XML/ARCHIVE)

• Going forward run the Benefits ACA Correction Archive Process, which serves to rearchive only the records marked as errors

HRSD Step 8. Generate Corrected Submission File

31

Benefits ACA Correction Archive Process

Benefits ACA Transmission XML Generation Process

• Follow the same submission steps as outlined previously • Update transmission status and process subsequent error files,

repeating steps 5 through 8 as necessary • Once you receive an Accepted status you will update

transmission status a final time with just the Receipt ID (no Ack error XML file)

HRSD Step 9. Submit Corrected File to IRS

32

• Some Retiree spouse’s are designated as subscribers, so we must provide a 1095B to them instead of 1095C • Employer sponsored coverage is offered to a non-

employee/retiree or covered individual

• We have less than 15 of these – paper forms

mailed to IRS (less than 250 records limit requiring electronic filing) – Note that there’s no “Addendum” form for paper –

each mailing is considered a unique filing – just resend any that were missed

HRSD Step 10. Write-up 1094B and 1095B Forms

33

34

Resources

• My Oracle Support – Information Center: Oracle Advanced Benefits -

Affordable Care Act (All Application Versions) (Doc ID 2007993.2)

– US HCM & Benefits Affordable Care Act High Priority Alert (Doc ID 2052173.1)

ACA Reporting in Oracle EBS

35

• IRS Guide for Electronically Filing Affordable Care Act (ACA) Information Returns for Software Developers and Transmitters - IRS Publication 5165 document https://www.irs.gov/pub/irs-pdf/p5165.pdf Affordable Care Act Tax Provisions for Employers https://www.irs.gov/affordable-care-act/employers Identifying Full-time Employees https://www.irs.gov/affordable-care-act/employers/identifying-full-time-employees Questions and Answers

ACA Reporting in Oracle EBS

36

• Form 1095-C Line 14, 15, and 16 code “Cheat Sheet” https://performancehcm.com/wp-content/uploads/2017/11/ACACodeList.pdf

ACA Reporting in Oracle EBS

37

38

Tips & Lessons Learned

• Subscribe To IRS Quick Alerts for AIR https://www.irs.gov/e-file-providers/subscribe-to-quick-alerts -Responsible Officials should also subscribe

• Hot Topics alerts for My Oracle Support (My Account > Personal > Hot Topics E-Mail) US HCM & Benefits Affordable Care Act High Priority Alert (Doc ID 2052173.1)

Tips & Lessons Learned

39

• Start early, make a schedule

• Meet regularly to help audit, stay on track

Tips & Lessons Learned

40

Tasks and Deadlines Assigned to 2018 Filing: Key Dates

2019 Filing: Target Dates

Order self-malier forms Kathy, Danielle 12/15/2017 on or before 12/21/18

Receive CIGNA files Inda 12/28/2017 on or before 1/15/19

Run ACA reports Robyn 1/5/2018 on or before 1/15/19

IRS Deadline for 1095-C Distribution IRS 3/2/2018 on or before 3/4/2019

HRSD 1095-C distribution (self-mailer form) HR, Mailroom 2/16/2018 2/19/19-2/22/19

HRSD 1095-B distribution (paper form) HR, Mailroom 2/28/18 2/19/19-2/22/19

IRS Deadline for paper filing 1094/5-B IRS 2/28/2018 on or before 2/28/2019

IRS Deadline for electronic filing 1094/5-C IRS 4/2/2018 on or before 4/1/2019

HRSD electronic filing (Accepted with Errors) Robyn, Kathy 3/12/2018 on or before 3/12/19

HRSD correction filing (Accepted) Robyn, Kathy 4/19/2018 on or before 4/15/19

• While auditing 1095C forms - make and keep notes on how issues were resolved, and what you expect codes to be in uncommon scenarios – HRSD examples:

EE’s hired after Dec 1st have no form as there was no offer in December

EE hired mid-month and terminated in the next month, had coverage for one month; will show 1G in box 14 for all 12 months as they were not employed for any month in year

Difference in codes for the month of termination for EE’s who had coverage vs EE’s without coverage

Tips & Lessons Learned

41

• Don’t wait until last minute to electronically file! • If Rejected by IRS:

– Need to time submit SR’s for issues

HRSD Rejections, 2016: – Incorrect schema – Oracle supplied a patch to correct – Invalid City names available for use in EBS, Correction

Archive did not include the updated City in the submission We manually corrected the XML file data (~6 persons) Get the new file size of the XML file (in bytes) Generate an MD5 checksum for the

ChecksumAugmentationNum in the manifest

Tips & Lessons Learned

42

• If Rejected by IRS, if you update transmission status to Rejected then all 1095C forms will be marked as corrected

Tips & Lessons Learned

43

44

Questions?