Keith: Good morning everyone. This is Keith Wayland from RPI Consultants. I want to thank you for taking the time to join us for this presentation on all things ACA. We have a whole series of webinars today, mostly focused around HR for the Lawson Customer Space. We hope you are able to join us for those. Presenting right now at 10AM Eastern, we have Miss Paula Brody, Miss Guyla Grover and Miss Lisa Cokes. Very excited to talk about this topic that’s concerning a lot of folks right now.
Before I hand it over I have three housekeeping notes. The first is that you should be seeing a live video broadcast. You should be able to toggle between the Power Point and the video feed as you like. The second is that because this presentation has a lot of content and steps, we welcome all questions, but we’re going to save them towards the end. Please type them in as you think them up into the Go To Webinar questions box and we’ll ask them towards the end.
If there’s anything we missed for whatever reason, you can always reach out to us afterwards. Third and most importantly, we are recording this session. We’ll be putting in on YouTube and our website and distributing that link. It usually takes us a couple of days to get up there, but it will be available for you and your colleagues to view later. Hopefully you find this a very useful presentation. Without further ado, I give you Paula, Guyla, and Lisa.
Paula: Thanks Keith and good morning to everyone. We’ve had so many requests about some questions around ACA. We’ve had a lot of clients that have asked what we can do to help them to get started with ACA. I think a lot of you already know that Infor has released the first of the patches. We have heard that the second patch is going to be released within the next week or so. Again, no date yet has been determined, but I do want to let you know that that second patch is in fact coming on out shortly.
One of the things that we wanted to just kind of give you an idea of is: where do I start, where do I go, where do I get the information that I need in order to go ahead and comply with the new Affordable Healthcare Act. Again, once as I have already mentioned, Infor has already released the first of the patchs. Along with that patch they also release a lot of different KB articles.
The first thing that you want to make sure that you go out and do is to go on out to Infor Extreme. As you can see we have listed here all of the different KB articles. There is also a master article in there that goes ahead and gives you everything that you need to know step by step. First thing is to go on out to the Infor site and take a look at all the different KB articles.
The second thing that you want to go ahead and do is, as you know, if you’ve started to look at this on your BN15.3 screen, you’re going to have to go ahead and put in your offer codes and your safe harbor code. The question is, where do I even go to get those codes? Again, this is information that is going to be out on the IRS site, so the information that we’ve culled here that actually give you the definitions for those codes are actually out on the IRS site.
You’re going to go through there and make sure that you determine which of the offer codes and the safe harbor codes are going to go ahead and meet the compliance piece that you need to identify on your BN15 screens. Again, as you can see, there’s a lot of content in there so one of the things that you’re going to need to do, which is your final step, is to actually have a discussion with your legal counsel and your HR directors and mangers and talk about which is the right code for you to use.
Again, this is something that we can’t necessarily help you with. It’s something that you have to determine internally, but again, what we have provided you is links in order to go on out and get those codes for you to go ahead and review. Then finally what we’re advising is to make sure that you go on out to the actual IRS site publication. Again, we have the link here listed for you.
This gives you all of the information that you should need in order to go ahead and understand and comply with the Affordable Care Act. With that being said I’m going to turn it on over to Guyla.
Guyla: Hi. Good morning. What do clients need to think about before starting the ACA implication? We have some guidelines steps here that we’re going to go through and briefly give you a description on each. We’re going to talk about setting up your ACA pay class and determining your best plan and your most affordable coverage plans and setting up waiver plans and recommending active enrollment and talking about compliance.
First thing I want to talk about is creating your ACA pay class which should be one of your very first steps that you do in your ACA set up. Your ACA pay class will then be attached to your pay summary groups. There’s a list that you can get from the IRS that has the list of pay summary groups, definitions that you need to be thinking about, your regular pay, your holiday pay, your jury duty, bereavement. That type of pay, so that way when your pay class is, when you run your PR197 and your pay class will go then to those PR time records and get their correct data.
Active enrollment and determining … One of the benefits of processing active enrollment is that you don’t have to think about the response of … We’ll skip to waivers.
Paula: Do you want me to go ahead and tell them while that’s on there?
Guyla: I kind of got lost on that.
Paula: Yeah, no worries. One of the things that people haven’t really thought about is the fact that for many that have been doing the Lawson S3, we’ve been doing passive enrollments. Meaning that you just carry over whatever your election has been from year to year. In the past, normally you run your BN105 and you stop your benefits for the current year and you just go ahead and move everybody on over into the next year.
Whether or not you do it this year or if not, you’re going to have to do it next year because of the compliance aspect of it. You actually have to be able to show that somebody has actively waived their enrollment, so this is really what this is all about is the fact of you actually now have to be able to capture that somebody has actively waived their benefits.
Then the other piece on this that has to take place is because of the fact that again, we need to be able to show once again what people have elected and more importantly, whether or not they have been made aware of the fact of which is the best plan. As we had talked about and we actually had a conversation, a lengthy conversation about this yesterday is the fact that one of the things that you also have to do as part of your enrollment is to let everybody know what is the best plan.
They don’t have to necessarily elect the best plan, but they actually do have to be advised of it. Whether or not again you’re doing the active enrollment this year, if you don’t do it this year and you’ve already gone through your open enrollment and capturing that one to eventually load in next year for 2016, you will actually have to make everybody go through an active open enrollment.
Lisa: Good morning. I would like to discuss high level configuring ACA. The first thing that you will need to do is populate BN00.5. Then after that’s populated, and that’s the ACA parameters, that’s what that form is called. Then you will go to BN15, select your ACA tab which is 15.3 and populate that. There you will put your priority for each HL plan.
Once that is complete you will upload your offers through BN729 which reduces to two files, one being an error file. Things that will go out of that file will be terminations or people who have actually changed plans during the year. Then you would also at that point load BN954 which is another configuration file that compiles the PR time information into the system. That information will go into a BN54 form which will be used in other processes that you do throughout the system.
Determining what is your best plan. If you are fully insured your provider should be able to provide the best plan. If self-insured you will need to make this determination. On the BN15.3 you will assign the prioritization as to what is the best plan. If they are fully insured, the carrier should be able to provide the best plan. If self-insured, client will need to make this determination.
Guyla: Compliance, we’re going to talk about compliance a little bit and what will happen if you don’t comply. There are two major categories that you want to think about. There’s offering benefit plans that are not affordable to your employees and also not offering the coverage that first, that you can afford. Then if you’re meeting the coverage levels requirements, minimum requirements that the IRS has put out.
Then there’s different penalties. There’s penalties, I believe it’s $2,000 an employee for a penalty for not complying. It’s $3,000 an employee for not giving them affordable coverage. Affordable coverage is, it goes by income, gross, your gross income or 9.6% of your gross income or your family income.
Paula: All right, dependents. One of the things that people need to be doing as well within the next year is actually getting their dependents’ social security numbers. Again, the reason why you need to do this is it’s actually going to be required for the 1095C. What we’re suggesting is that you go on out and make sure that whether or not you’re doing it through your self-service or if you’re doing it through a third party provider, make sure that you are going out there, getting all of your dependent coverage updated and making sure that you actually update that with their social security number.
Again, as far as from the S3 side, again, that would be updating your HR13. What is happening next? A couple of different things as we mentioned at the very beginning. The next CTP will be coming on out within the next few weeks. Then we also want to make sure, and this is one of the things that I’ve had a lot of clients say that they didn’t realize is that they were going to have to be working with a third party provider for the generation of the 1095C.
I think probably a lot of you have seen that MHC and ADP have both been offering webinars talking about the services that they’re offering regarding that generation of that file for you. Again, this is something that you will need to be working with a third party. That this is not something that Infor itself will help you produce.
I want to make sure that everybody is going on out and making sure that they’ve already started that discussion. Again, it’s going to be one of those things where they’re going to be looking for that in conjunction with a production of the W-2. With that being said we also want to then give everybody an opportunity. I know that more than anything people seem to have a lot of questions around the Affordable Care Act.
Again, this was meant to be a high level of some of the questions that we’ve already had working with a lot of our clients, but now is the time for you to go ahead and ask because we have two great resources with Guyla and Lisa that are actually actively working with clients right now in order to make sure that they are getting their ACA patch in and working.
Keith: First of all I want to thank you guys for this overview here on ACA with Lawson. We do have a few questions. I’m going to start sort of in order here. Is there a reason why I need to create a new pay class or just use an existing one if it meets the needs?
Paula: That’s totally understandable for those of us, so a lot of you already have a pay class out there that you’re using for payroll purposes where you’re absolutely already capturing this information, but my understanding and Lisa, Guyla, correct me if I’m wrong, but I do believe that you actually have to create a new pay class specifically for ACA. Is that correct?
Lisa: It makes it easier for you to identify. ACA is a separate animal from everything else, so it just makes it easier for you to identify.
Paula: Great. Thanks.
Keith: Okay, then the next question is pretty detailed here. The 1095C form part 2 requires offer codes and safe harbor codes for each employee for each month of the year. The current Infor patch allows you to assign a safe harbor code to each plan, but that does not take into account the fact that those codes may change from month to month for a single employee. Do future releases address this issue? I’m not sure if we’re in a position to answer that. We’ll have to defer to Infor on that.
Paula: We do, but let me just mention, because again, this is one of the things that we were having our conversation about yesterday. That was, I think Lisa, you were the one that pointed it out. I believe it was on BN19.5 where you can actually override the safe harbor.
Lisa: Absolutely. Yes.
Paula: … and the offer code.
Paula: I do want to make sure that people are aware that they can go on out. Again, this is going to apply to the plan and not to the individual, but again, you can go on out to that particular form if you need to on a monthly basis or on whatever basis that you need to and update that information.
Keith: Okay. Here, I understand you said that our insurance provider should be able to tell us what is the best plan. Can you help with an exact definition of what that means? What would make one plan have more coverage than another? Is it a cost or the premium, that key determinant?
Lisa: It’s both. Basically, really that’s something that the Internal Revenue Service provides that information. If you cannot find that information online I would suggest that you contact the Internal Revenue Service and ask them that question directly, because they really can tell you that information, if it is cost effective and the coverage is a good coverage.
Keith: Right. There’s probably some more complicated requirements.
Lisa: It is.
Keith: You might want to check with your insurance broker or company.
Lisa: It is. Safe harbor, yes.
Paula: As we have said, it actually should be if you are using a third party provider they should absolutely be able to tell you which one is the best plan.
Keith: Okay. We’ve got a lot of questions coming in here. Similar question on the best plan, so I think we’ve already … The [inaudible] Plan is confusing. I think we agree with that. Will the amount that shows as employee cost in the file, the BN729 be used on the 1095C form on line 15?
Lisa: The BN729 just uploads the offers. Basically who can be offered ACA. That information is coming through a file, it’s being picked up. Two files are produced from that. One file will be the one that you load through the system and it will go right to the BN29. Now, you can go in BN29 and you can delete and add as you choose.
Keith: Okay. These are all so over my head, I’m just doing my best I can here.
Paula: Go for it.
Keith: Usually I have a little more confidence. We are putting all the release patches into our production this weekend. Our open enrollment is over. Can we still use this new functionality to capture 2015 information? Would we need to go back to put in the waive plans for the 2015 records?
Lisa: Yes. You have to have waive plans for 2015.
Paula: We actually are seeing that with many of the clients out there, so as everybody knows the patches came on out. Many people were already starting open enrollment or very close to it, so they did not apply the patches during the open enrollment. They decided to wait until after. They do have files available. They do have the templates out there where you can go back and actually add in the information after the fact so that you will have it, but again, the only thing in there is I think that there’s something that has to be triggered for 2016 though.
Lisa: If you don’t currently have a waive plan set up in your benefits module, you would need to actually set up a waive plan in your benefits module.
Keith: We ran the offers and had many employees, oh I’m sorry. We ran the offers and had many employees fall in the exception report. Many were terminated, closed, went part time, et cetera. Is the expectation that we need to go through all termed employees and any change and load them back in?
Guyla: The termination, you’re expected to see those on the exception report. They will still show when you get to year end, your reports at the end. You will expect to see those employees on that report. That’s basically what it is that is showing you that these are people that have changed for some reason or another.
Keith: We are currently struggling with the measurement and assessment processing. Can you help define this?
Lisa: The measurement assessment, which is BN149, there are two tabs that you can fill out, either the initial tab or the standard tab. You basically only need to fill out the initial tab and the information from BN00.5 will automatically default to the standard tab.
Guyla: Just to elaborate a little bit on that, what that is doing is it’s looking for three months to a 12 month period to determine employees’ status of maybe they worked part time most of the time, but for two months in that time period they worked what seemed like full time. You’re not sure of how they’re going to show. That’s what that stabilization period does is it will determine for you how to calculate whether they’re considered FTs or not.
Keith: I don’t know if this is related so I’m going to ask it. What is the importance of measurement records? Are they used to produce the 1095C?
Paula: I’m not sure if I would say they’re used to produce a 1095C, but the measurement again, we were having this conversation this morning about this very exact thing, about what is measurement period. One of the things that really is driving that whole measurement period is around things like our seasonal workers or our part time workers to determine when somebody hits that thousand hour mark that we’ve talked about.
What that measurement period allows you to do is saying, and we were talking about and we think the recommendation should be that that measurement period is 12 months, but that would be again, something that you would need to determine internally if that’s the right thing for you. What it would do is say okay, if I had a seasonal worker that worked for me for four months full time, then either went to less than full time or actually terminated at the end, that measurement period would be taking that average over that 12 month period. That’s where that measurement period comes into play.
Keith: We’ve got more questions. I’m going to thank people for not holding back with the detail level here. This is a tough one. Our best plan is based upon where employees live by zip code or state. Of the 12 health plans we offer, five of them could potentially be the best offered to the employee based upon where they live. Any advice on how these variations can be set up with the new Lawson functionality?
Guyla: In that case I would check with your insurance providers and have them determine that for you, which they would consider to be your priority. You can prioritize them and what they say, okay, this is your best. That’s going to be number one. You can do the next one number two. If there’s people falling in the different categories. If you’re really not sure, check with your provider.
Keith: It sounds like they might know, but it’s based on location. It’s based on a variable. It’s not a global thing.
Lisa: They’re basically saying that they all would be priority one depending on where you live.
Guyla: You could pick one if they’re all the same, except for based on the location, yes.
Speaker 5: I don’t think it would be the same. They’re going to be different plans and …
Keith: Depending on the employee.
Speaker 5: How can they be set up so they’re going to be …
Guyla: Oh, they’re going to be different.
Speaker 5: … offered to each person by location?
Paula: I guess the question, and again, number one, please feel free to contact us where we can have the more in depth, but what I’m wondering is are they separate plans or is it one plan where it’s a different contribution rate based on location? There’s a lot of different things. If it’s 15 different plans because it’s each location then each of them would have, again, you’d set up the ACA on that particular plan on the BN15 and going in and putting in that information where again, you’re prioritizing. On each of those you would go ahead and put in a priority one on each of those different plans. That’s where I think that again, we’d need to get more detail to find out exactly what their set up is in order to be able to advise.
Keith: Yeah. Okay, I’m going to move on here to it does sound like it’s separate plans based upon location, but I’m going to move on here. Follow up to the 2015 records did you mention there’s some documentation on how to determine who needs a waive?
Paula: Well, I think we already talked about the fact that it’s actually, and Infor said the same thing months ago when they came on out with the patch, is that the first thing that everybody needed to do was make sure that they went out and set up a waive plan. Because the requirements state that a person has to actively waive.
In the past a lot of times what would happen is is that they would just set up a default plan where somebody would actually waive. Again, those don’t meet the requirements of that being a default. What happens is somebody actually has to go on in during open enrollment and hit that they have waived and they’re going to need to be able to show that for 2015. Again, they have to be able to record that it was actively waived.
Keith: I’m going to see how I can, my own, paraphrase this a bit. Thanks to RPI for offering this webinar. It sounds like there’s still a lot of moving parts with the ACA thing. Would you agree with that statement?
Paula: Absolutely. I don’t think that there is anybody that could dispute the fact that ACA is very complex. I will say this, Infor has done a tremendous job in trying to really stay ahead of it. I know that they’ve been waiting as well. The IRS has been slow in moving forward with providing the finalized forms, the 1095s and everything else which is actually been slowing everybody down, both Infor and the third party vendors that are actually producing the 1095s, but again, this is still kind of a moving part and everybody is still waiting to see what’s going to happen over the next, really the next two years around where all of this is going to be going.
Very complex, constantly moving, and like I said, as well, if you haven’t gone to any of the Infor webinars that they have done, the one thing that they have also said and they always emphasize is they actually have as well, for those that use Infor Extreme for your ticketing system, they actually have people staffed and ready to also answer a lot of your questions around your ACA set ups. Again, if you’re having problems with your set up, you can always as a first step go ahead and log a ticket with them and see if there’s something that they can help you with.
Keith: I’m going to keep going here. If an employee was part time years ago and then goes full time this year, if we use hire date on BN149 the only way they would be caught would be when the standard option is wrong. Is that correct?
Lisa: The standard option defaults from BN00.5, so it’s based on the requirements on BN00.5. if you have a 12 months period, then that information would default on the standard tab for that employee, the new hire.
Paula: If it’s a new hire date.
Lisa: If it’s a new hire date, yes. If it’s a new hire date. That’s true.
Keith: If the hire date predates the time when, sorry. I don’t know if the hire date is when they go full time or part time. That question could go both ways. If we have all our retirees and our participants in a separate database outside of Lawson I’ve been told that we would load them into Lawson using BN529 or BN729, but some don’t have employee ID numbers.
Guyla: Just had to throw that last piece in.
Lisa: They are going to have to have some identifier in order to get into Lawson. I’m not really sure how to …
Keith: You have to come up with some sort of number.
Lisa: Yeah, ID number, yeah.
Keith: 999 or whatever.
Lisa: That interface is still Lawson, correct
Keith: If our employees are full time and receive their insurance the first of the month, I almost feel like I’m reading a math question. Can the measurement, I’m sorry. If our employees are all full time and receive their insurance the first of the month following their hire date can the measurement period be 30 days? Do we need any numbers of administration or stabilization periods?
Lisa: Yes. You have to populate. Yes, is the answer to the question. Because you have to populate BN149 for measurements. I would actually have to ask some additional questions in order to completely answer that question about the 30 days. You do have to process BN149 within the process of ACA. Those questions, those fields that she’s asking about, those are directly related to the measurement.
Guyla: There is a field that’s in the BN15 in the ACA tab, the very last one down that you indicate when you actually start calculating. If you start the following month. Let’s say maybe they started work in the middle of August, but they didn’t actually start their enrollment until October 1st, then you would set that flag to yes on that very last field.
Lisa: Is that on the safe harbor on ACA tab?
Guyla: That’s on the ACA tab, yes.
Keith: All right, I’m going to ask one last question. Before I do I want to thank everyone for attending, participating, asking questions. I want to thank our presenters and obviously some of these questions are very detailed. If you want to take them offline, feel free to reach out to us. We’re always happy to chat and see if we can come up with creative solutions or be able to help.
Last one I’ve got here for this session. I don’t know if we addressed this somehow with one of the others, if we use a 12 month measurement period, can we use a three months administrative period or are we limited to a one month administrative period?
Guyla: Your administrative period needs to be a minimum, well, it has to be, most of them are 30, 60 or 90 days.
Keith: It can be three months.
Lisa: It can be, yes.
Keith: We believe the answer is yes. All right, with that I want to thank everyone. Really appreciate your time today and all your great questions. I want to thank Paula, Guyla and Lisa for a great presentation. Really appreciate your efforts here. Thank you.