On March 10, 2014, the Internal Revenue Service (IRS) published final Treasury regulations (Employer mandate - Section 4980H) for two separate information reporting requirements added to the Internal Revenue Code by the Patient Protection and Affordable Care Act of 2010, as amended (PPACA or ACA). Other sections of the code that come into play throughout the administration of IRC ₴6056 and IRC ₴6055 that specifically addressed the employer reporting. The act also included the requirements for employees. This section was referred to as the Individual mandate – IRC section 5000A and Premium Tax Credits IRC section 36B.
July 24, 2014 the IRS published draft forms to address reporting. The IRS finalized these forms on February 4, 2015. Final versions of forms 1094-C and 1095-C with instructions were published on the IRS Forms and Publications website for 2014. Forms and Instructions for 2015 are still to be published by the IRS along with the electronic filing requirements for 2015.
IRC₴ 6056 Applicable Large Employers (ALE) with at least 50 full-time employees (& FTE) are required to report to the IRS information about minimal essential healthcare coverage, if any, they offered to full-time employees (30 hours or more) in order to administer the employer share responsibility provisions of section 4980H. These employers must also furnish form 1095-C statements (Parts I & III) to employees offered benefit coverage for use when filing their 2015 Form 1040. Employers also file a copy of these forms 1095-C with the IRS.
IRC₴ 6055 addresses health insurance insurers, self-insured employers and others that provide minimal essential healthcare coverage to individuals. Self-insured benefit customers also follow these provisions. These Employers also file forms 1095-C but additionally provide information in Part III of the form on who is covered under the plan and period(s) of coverage. These employers must also furnish form 1095-C statements to employees offered benefit coverage for use when filing their 2015 Form 1040. Employers also file a copy of these forms 1095-C with the IRS.
The Benefit Offer reporting is done annually, following calendar year cycle just like Payroll does for W2 Processing. ACA has therefore, created a new Benefit Year End process that will be the responsibility of your Benefits team. Reporting of the Benefit Offer 1095-C forms was optional for Tax Year (TY) 2014. Infor did not support this reporting.
Speak with your legal counsel to determine which provision(s) apply to your situation. Infor’s software provides functionality to support these regulations but in no way should Infor’s software or information published about our software updates to support compliance be construed as tax advice.
The ACA has created a new, year end process around information reporting on Benefit Offers. To assist customers with the new Benefits Year End reporting, Infor has created enhancements to the Benefits Administration module. Customers must be licensed for and using the Infor Human Resource Benefits Administration module to product the Employee and Employer ACA Reporting.
IThe CTP for Benefits Administration module enhancements for ACA is on target for early September delivery. This enhancement CTP is being delivered as an Installation Alert through Xtreme Support. The contents of this CTP provides the Data Collections and Measurement Assessment components needed to prepare the file for 2015 ACA Reporting on Form 1095-C. This reporting requires Benefit Offer data and other components to be in place before the actual reports can be created. Documentation, form and field help will be be provided as part of the CTP delivery by Infor. This CPT includes features to assist customers with classifying plans, re-creating Benefit Offers and establishing measurement period information. These programs also put in place features needed to manage your benefit offers, on-going changes, gather hours, and track new hires/rehires for Calendar year 2016. Customers need to subscribe to receive the Installation Alert notification through Xtreme.
The actual ACA Employee and Employer Reporting enhancements CTP will also be released as an Installation Alert, but not until early December coincident with the Year End Regulatory Release. The September CTP is a PREREQUIST to the December CTP. In order for the ACA Reporting to work, the September CTP must be applied and the benefit offer data created and validated.
The recreation of offers and validation can take some time to complete (varies by customer). Customers need to take the September CTP as soon as possible and begin preparing their data now. DO NOT wait until December to begin this process.
For more information on the ACA delivery, you can refer to KB 1650062 – HRM Benefits update for the Affordable Care Act.
By this communication Infor does not intend to provide legal or regulatory advice or recommendations, nor should this communication or information contained in the links identified herein be construed as imparting such advice or recommendations regarding the Affordable Care Act or other laws, rules and/or regulations. Customers are solely responsible for complying with all laws, rules and regulations and should consult a professional advisor should questions or issues arise.
This announcement reflects the direction Infor may take with regard to the specific product(s) described herein, all of which is subject to change by Infor in its sole discretion, with or without notice to you. This announcement is not a commitment to you in any way and you should not rely on this document or any of its content in making any decision. Infor is not committing to develop or deliver any specified enhancement, upgrade, product or functionality, even if such is described in this announcement and even if such description is accompanied by words such as “anticipate,” “believe,” “expect,” “intend,” “may,” “plan,” “project,” “predict,” “should,” “will,” and/or similar expressions. Many factors can affect Infor’s product development plans and the nature, content and timing of future product releases, all of which remain in the sole discretion of Infor. This announcement, in whole or in part, may not be incorporated into any contractual agreement with Infor or its subsidiaries or affiliates. Infor expressly disclaims any liability with respect to this announcement.
Spotlight on Infor Solutions
Learn how Infor is enhancing its systems to prepare for ACA compliance reporting for Benefits Year End 2015.
View the Statement of Direction
Infor wants you to stay informed. Check back frequently for the latest updates on ACA components to support 2015 Year End Reporting for Benefit offers.
Also visit www.inforcommunities.com to become a member of the HCM community, where you can subscribe to announcements and discussions.
What’s New for the Affordable Care Act in Infor HCM
Learn what Infor is doing to help you prepare for and manage Affordable Care Act requirements. Review the ACA requirements already in place as well as the mandates for 2015, and hear how Infor is enhancing its systems to prepare for upcoming compliance deadlines.Click to view webinar
Q&A for Offers of Employer Health Coverage (Section 6056)Click to view
Q&A for Offers made by Self-Insured Employers (Section 6055)Click to view
Shared Responsibility for Employers Regarding Health Coverage
For the final regulations under section 4980H see T.D. 9655, 2014-9 I.R.B. 541Click to view