The Affordable Care Act (ACA) has been one of the most hotly debated pieces of legislation in a generation. While some congress members have made dismantling ACA their full time job, its implementation continues to challenge HR and Payroll departments nationwide, not to mention the software publishers that support them. And Kronos is no exception. Every couple of years there is a new fact of ACA that HR and Payroll departments are required to implement, leaving many struggling to figure out how best to modify their HR and Payroll tracking and reporting to comply. In 2012 it was the reporting of health care costs in W-2 Box 12 Code DD. This year—2015—it is implementation of ACA rules regarding benefit eligibility.
The Affordable Care act requires large employers and providers of minimum essential coverage to meet certain reporting requirements. Insurers, self-insured employers, and government programs must provide 1095-B statements to individuals and file copies with the Internal Revenue Service (IRS) to verify that individuals have minimum essential coverage that complies with the individual responsibility requirement.
Form 1095-C statements must be provided to employees and filed with the IRS by employers with 50 or more full-time or full-time equivalent employees. These forms ensure the employer’s compliance with the employer responsibility requirement and the employee’s compliance with the individual responsibility requirement.
These reports were set to be filed in early 2015 for the 2014 reporting year, but have been delayed for a year. December 28th, 2015, the IRS issued a notice that changed the dates, delaying the reporting requirement by only a couple months. . The due date for providing the 1095-B and 1095-C statements to individuals were delayed from February 1, 2015 to March 31, 2015, and the due date for filing the forms, plus the 1094-B and 1094-C transmittal forms with the IRS was delayed from February 29, 2016 to May 31, 2016 (or from March 31, 2016 to June 30, 2016 for electronic filings).
The additional time was deemed necessary by the Department of the Treasury, after it was concluded that all parties needed additional time to adapt and implement the systems, gather the information, and report the information. Employers and coverage providers are encouraged to provide returns and statements as soon as they are able to do so.
Where does Kronos fit in?
Your Kronos Workforce system is the primary tool used for analyzing available resources and budgeting. Thus, you rely on the HR Employment Status page to flag each employee as full time or otherwise. But now, the ACA throws an additional consideration into the mix, which employees are eligible health care coverage under your plan.
The obvious challenge here is that not all employers consider 30 hours per week to be full time for administrative purposes. Yet, your current HR system may have flagged all employees as full time, or not, based upon your current definition. So now there is full time as defined by you, the employer, and full time defined for ACA benefit eligibility purposes.
Good news for Kronos HR users: An ACA Full Time Status field has been added to facilitate the tracking of current, and historical, full time status for ACA purposes. And that field can also be used to track Benefit Plan eligibility criteria. The following versions of Kronos HR have deployed this feature for your use:
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Kronos HR 6.2.17
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Kronos HR 6.3.14 [Assumed, but not yet released]
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Kronos HR 7.0.6
Because full time status for ACA may not coincide with your organization’s policy, Kronos has created a separate page for tracking this information and its history. If you are already operational with Kronos Workforce HR, you may be best served by using an application consultant to help you plan, configure, and deploy the records required to use this new feature added by Kronos.
Once you have the new ACA Full Time Status field setup and deployed for all employees, you can review the configuration of your benefit plans to determine that they are configured appropriately to meet ACA eligibility requirements. If changes are required, an application consultant can further help you update your benefit eligibility requirements.
While you may have already had to make do with your current configuration for benefit enrollments that took affect January 1, 2015, it is not too late to configure and begin using the new field for tracking. And Improvizations is here to help.
Download our FLSA Compliance Recommendations PDF for more information on ACA/FLSA best practices:
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