Health Care Reform Reporting requirements (ACA)

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.