ACA Frequently Asked Questions

ACA Frequently Asked Questions

Overview

Understanding the Employer Shared Responsibility provision of the Affordable Care Act (ACA) is essential for correct reporting by large employers with employer-sponsored health plans.

Applicable large employers (ALEs), employers with 50 or more full-time employees (full-time is 30 hours or more), must provide eligible employees the option to enroll in employer sponsored health benefits. Employers may be assessed fines if coverage is not offered to eligible employees.

To learn more, read the common questions and answers.

Information You Need to Track Now

The information you should be tracking now FAQs.

Does PPACA require all employees to be tracked or only those not currently meeting the full-time employee threshold?
Employers need to offer health insurance coverage to full-time employees and report who was offered health coverage. The IRS definition of full-time is 30 hours or more per week. Employers with variable hour and/or seasonal employees are encouraged to use the Healthcare Measurement tools in your UKG Pro™ solution to identify employees who are eligible for the offer of coverage. 
Which data fields do we need to capture now to account for full-time/part-time employees?
You can use the new Offer of Coverage page to track the offer of coverage, minimum cost for self-only coverage and safe harbor codes on a monthly basis for each eligible full-time employee for each month of the reporting year.
Is the minimum cost required to be filled in even if they are not covered?
The instructions on the form specify when the minimum cost is required to be filled in; it depends on the code used for offer of coverage.
Do we need to track offer of coverage information for EACH employee for form generation? Can the system not pull this from the benefits or open enrollment data?
Yes, you need to track this information for each employee. The benefits or open enrollment data cannot be used because it only provides information on who has accepted an offer of coverage; but, does not provide data on all those employees who were offered coverage, including those who did not enroll. The IRS reporting requires you to include all employees who were offered or should have been offered health insurance coverage.
If an employer chooses to offer appropriate benefits to all full-time and part-time staff, does the employer still need to track all the monthly time data for IRS reporting?
You need to track which employees are considered full-time based on the IRS requirements. Then, for each full-time employee, you need to track the type of offer of coverage (using the associated offer of coverage code) that was made to full-time employees for each month. If you are a self-insured employer and offered part-time staff coverage, you need to complete Part III of Form 1095-C for employees who accepted coverage.
Is it the responsibility of the employer or the insurance company to gather employee and dependents social security numbers when submitting the required reports?
If you are filing as an employer, you need to gather the employee and dependents information.
Is a non-profit church that is self-insured subject to reporting?
If you have 50 or more full-time or full-time equivalent employees, then, yes, you are subject to reporting.
Our organization gives employees Health & Welfare dollars to pay for coverage and this covers employees’ cost. As an employer, do we enter an amount of $0 for the employee portion?
UKG recommends that you discuss this with your legal counsel. The IRS, DOL, and HHS have rules around providing your employees with money to purchase health coverage rather than directly providing coverage.
Would we need to track non-employee COBRA participants (ex-source, over-age children)?
Yes, if you are self-insured.
If you have union employees covered by a union health plan, must they be reported as well?
Employers must offer health coverage to all eligible full-time employees who meet the IRS requirement.
Will a checklist be available?
Yes, a checklist will be available to ensure the client is on the right path of successfully completely all aspects of ACA. It is available under Reporting > ACA Manager > Checklist. 

Open Enrollment and Life Events

Open Enrollment and Life Event FAQs

UKG Pro's Open Enrollment feature lists employees who enroll and decline healthcare plans. What additional information is needed for the offer of coverage?
There is a specific list of 9 codes for ACA reporting listed in the instructions for Form 1095-C with regards to the offer of coverage. This type of information is not stored in your UKG Pro solution.
Why can the individual forms not be auto-generated at least for all of the employees who have accepted medical benefits? That way, we would not have to complete each employee form manually?
The system does not track who coverage was offered to, it only covers employees who either accepted or declined. Employers must report offers of coverage that was provided to all full-time employees.
Do employers need to use Open Enrollment or Life Events for data to flow into these forms?
No, the ACA requires employers to report offers of health insurance coverage made to eligible employees using the Form 1095-C – Employer-Provided Health Insurance Offer and Coverage. Employers do not need to use Open Enrollment or Life Events to obtain the data needed for IRS reporting. Open Enrollment (OE) and Life Events (LE) provide employees with enrollment information and an opportunity to enroll in health plans. Employers only need to report the details of the offer and coverage of health insurance. Note: Should you use OE or LE in your UKG Pro solution, you can configure certain health plans to be presented to employees who are eligible under ACA.
If we run Open Enrollment using our UKG Pro solution, does that not suffice as evidence of an offer?
With regards to offering coverage, you must provide employees with the ability to enroll or decline coverage. The ability to report from the emails that are sent via the open enrollment sessions will be provided.
If we do not use Open Enrollment or Life Events, will this impact our ability to leverage our UKG Pro solution for reporting purposes?
The Offer of Coverage page and the imports will be sufficient to populate the required information.
Under HIPAA, we offer coverage during annual enrollment; do we "offer" coverage all 12 months if we had an annual enrollment available to all eligible employees?
ACA requires employers to offer health insurance coverage to full-time employees and report the details of who was offered coverage. Providing employees with the opportunity to enroll can be done on an annual basis. You will still need to track seasonal or variable hour employees who may be eligible some months and not others.
At the benefit code level, we have the dependents listed with the enrollment date and cancellation date (if applicable) listed as well. Will this information be used by the system?
This information will be used if you are a self-insured employer for Part III of Form 1095-C for the employee.
What constitutes an “affordable” cost? Is there a rule specifying a number or percentage?
The cost for self-only coverage cannot exceed 9.5% of the employee's household income. There are also 3 safe harbor provisions employers can use.
How will our UKG Pro solution track termed employees who enroll in COBRA?
There are 3 options available:
  1. Import the Cobra coverage for UKG Pro terminated employees using the Covered Individuals Import Template (Part III of the Form 109-C).
  2. Import the Cobra coverage for Non-UKG Pro terminated employees using the Non-Employee Import Template (This template is designed to provide a Form 1095-C to a person that is NOT in your UKG Pro solution). For example, an employee retired 20 years ago and is on Self-Insured Cobra coverage, however the employer went live on their UKG Pro solution 5 years ago and this terminated employee is NOT in your UKG Pro solution.
  3. Track the terminated employee’s benefit coverage using your UKG Pro solution.
How will the system know which is the lowest cost plan offered to the employee if your company has many rate structures by work site?
You may use the federal poverty line as one of the safe harbors to address this scenario.
I have component companies that are each unrelated business entities, but all fit under one master company. Is there any documentation on how to configure an ALE group which can produce Form 1094-Cs based on Component Company, even if they are separate ALE members per FEIN?
If they are all separate legal entities and not part of a controlled group, there is no need to setup an ALE Group. They would select “Component Company” as the ALE option on the PPACA Reporting Settings page, and create individual ALE Members for each of their component companies. They would each get their own Form 1094-C and corresponding Form 1095-Cs.

Web Import Template

Web Import Template FAQs

Where will the Business Intelligence Import Template be available?
The import template(s) are available via the UKG Pro portal. There are three parts to Form 1095-C:
  • Part 1 - Existing data in your UKG Pro solution is used to populate Part 1 for employees active in the UKG Pro solution for at least one month in the report year.
    Note The information for non-active employees (Cobra, non-employees, and retirees) must be imported using the Import template to populate Part 1.
  • Part 2 – This information must be imported using the import template or added manually on the employee’s offer of coverage page.
  • Part 3 – This information is automatically generated if you use your UKG Pro solution. If you use a third-party Benefits provider, then this data can be imported.
If a mistake is made from an ACA import (or not), can they reimport and will the data be overwritten?
Customers are able to re-import data and the data are overwritten.
Will there be some reporting available for employers so information can be retrieved from the system and the data mass populate and/or be imported for each employee, per month?
Yes, with the delivery of the import template(s) in the form of BI Report templates, customers can review the information that has already been manually entered into the UKG Pro solution. Any data that has not been manually entered displays as a blank field in the BI Report templates.
Is there an audit for the import?
There is no specific audit, but you are able to see the username and time stamp of the last time the import ran by selecting the filename link.
Will the associated covered dependents data come into the web Import template?
If the information is in the system already, it populates automatically. If the information is not in the system, use the appropriate BI import template to import the data for Section III Dependent Detail for Form 1095-C.

Health Care Measurement Tools

Health Care Measurement Tools FAQs

We use a different Time Management solution; can we still use the healthcare measurement tools in our UKG Pro solution?
If you import time and run Payroll in your UKG Pro solution, then you can use the Healthcare Measurement Tools to track eligibility based on payroll records.
Why am I seeing duplicate records on the Health Care Eligibility Summary grid?
If an employee is deemed a new hire, they will be measured with a new hire period that starts on their hire date (or first of month after). In addition, there may be a standard period that begins during the new hire period, but must be applied to the employee to measure their average hours to determine eligibility once their new hire stability period ends. You may see a New Hire period, as well as a Standard period that are active for an employee at the same time.
Why is my Coverage Stability Period different than what I set up on my HCE Group?
When you have an employee being measured OR has been measured and is currently being covered, there can never be an overlap in coverage. So, where one coverage period ends, the next one begin, in spite of how this was setup by the administrator. It will never extend past the Coverage Stability End Date unless there is another Standard Period created. For example, if the last created Standard Period ends on 5/31/17-- that is as far as the employee’s coverage will go until the next Measurement period is created and they are added to the group. (Sometimes, you will not see the data on the HCE Summary, hence, you will need to go to the employee’s Profile > Benefits > Health Care Eligibility).
How do I know if I have the healthcare measurement tools and is there a cost associated?
The healthcare measurement tools are part of the UKG Pro solution; there is no additional cost associated with using the tools.
Must customers configure the healthcare measurement tool in the UKG Pro solution if reporting hours to a third-party who will be handling ACA reporting requirements?
We recommend you use the healthcare measurement tool for seasonal or variable hour employees to help identify employees who meet the full-time hour threshold (30 hours per week or 130 hours per month) for the offer of coverage. Note: Using the healthcare measurement tool is not required in order to complete IRS reporting.
Would a rehire remain in their same measurement group and begin tracking when rehired or should they be in a different group?
Depending on the scenario, refer to the following:
  • Employees rehired into the same company as before will continue to be measured based on rules in the measurement group to which they are assigned and their original hire date.
  • To assign a new measurement period to a rehire, you must remove and re-assign the measurement group to the employee.
  • Rehires into a new company which they were not in before, or where they did not have a measurement group, will not be automatically associated with a group in that company.
If we have salaried employees who do not have hours, can we still use the measurement tool to track hours? I am currently using my own method to track hours.
The measurement tool uses payroll hours. As long as you continue to capture payroll hours in the UKG Pro solution and you know which employees must be offered coverage, your method should work. The main purpose of the measurement tool is to track seasonal or variable hour employees to determine full-time eligibility (30 hours or more per week) based on IRS requirements. If you have full-time salaried employees, you likely do not need to use the measurement tool.
Can you exclude certain “hours” from being collected for the healthcare eligibility purposes?
Yes, you must flag the earnings codes to be included in the healthcare eligibility calculation.
Does the hour tracker account for those hours that are considered a leave of absence?
The hour tracker uses payroll hours.
If a salaried employee does not have hours entered into payroll, does that mean the employee’s hours cannot be tracked in the measurement tool?
Yes.
If tracking all employees and the respect health care eligibility status for the deduction/benefit plan is configured to Yes, will a full-time employee be able to enroll in a benefit plan via OE/LE even though their eligibility status is still “Pending”?
When using the health care measurement tool in conjunction with a deduction/benefit plan configured as eligible under PPACA, if an employee’s health care eligibility (HCE) status is NO or PENDING then the employee will not be able to enroll in that plan. For more information, refer to the Health Care Eligibility Under PPACA topic available from the Benefits release webcast. Employers also have an option to define eligibility for benefits during the enrollment process even if the HCE status is Pending.
Once I configure a Health Care Measurement Group, can I change the start/end dates of any of the measurement, administrative, stability periods once I have employees assigned to the group?
For the dates set up for new hires at the Measurement Group Business Rule level, you can make changes. Those changes apply to any subsequent new hires assigned to the group. For the standard period dates, if there are employees assigned to the group, you cannot make changes to the standard period dates. You can do a mass un-assign, change the dates, then mass re-assign employees, or set up a new group all together.
Why is my New Hire Administrative Period different from what I have configure?
There is a government mandate that the initial measurement period and the administrative period combined may not extend beyond the last day of the first calendar month beginning on or after the one-year anniversary of the employee’s start date – this is the boundary date of the employee’s initial admin period. Therefore, if the calculated end date of an employee’s initial administrative period is beyond this mandated boundary, we will automatically move the administrative end date back to the boundary date. So if you look at the above example, the NH Admin Period is different from what the Admin originally set up. They chose End of 2nd Month after Measurement Period which in this case would be 5/31, not 4/30. However, the employee’s hire date is 3/14 so since it cannot extend beyond the last day of the month beginning on /after the 1year anniversary, then the Admin Period will adjust itself (basically a total of 13 months from the last hire date) 
Why am I not seeing an administrative period for some of my employees?
The IRS mandate states that the measurement period and administrative period combined may not extend beyond the end of the month that falls on or after the employee’s one year anniversary date. If this occurs, we push the end of the measurement or admin period back to this boundary date.
  • For example, if an employee is hired on 8/1/2013, this boundary date is 9/30/2014. The measurement plus admin period cannot extend beyond this boundary date. If the measurement group rule says to start the measurement the first of the month after hire date for 12 months, then the measurement period will extend from 9/1/2013 to 9/30/2014, which means there cannot be an administrative period for this employee.
  • This rule by the IRS is meant to not have new hires wait more than 14 months to be offered coverage.
If I complete a void or negative hours, should it not be considered in the calculation for HCE?
All voids will be included as long as they are done during the measurement period. Once the measurement period has lapsed and is closed and eligibility is determined, any subsequent voids or adjustments that affect pay periods in that closed measurement will not be picked up.
If a certain type of leave (i.e., “military leave”) is being considered for hours for the HCE, should the client use a separate earn code not marked for calculating HCE?
Yes, a separate earning code is exactly how they should handle any type of leave that they don't want to include in the calculation of HCE average hours.
What is the best process to add new hires to the appropriate measurement group? What is the best process to add new hires to the appropriate measurement group?
We are suggesting to our customers to run a report once a month to identify all of the new employees that were hired in the past month, and which are part time/variable hour employees that need to be added to a measurement group. Then, they can use the mass assigning feature. Under Employee Admin > Health Care Eligibility Groups, you would assign the employees to the appropriate measurement group. Once the employees are assigned to the measurement group during the measurement period, the nightly job will go back to the hire date of the employees and start measuring their average hours.
When an employee on HCE report has already passed their New Hire measurement period and already has an eligibility status, will that EE drop off of the report?
It will drop off the report as soon as their Coverage Stability Period starts. The idea is that while they are in the admin period, the manager/admin needs visibility of that employee to offer the eligible people health benefits.
How is the Eligibility Status updated?
In order for the eligibility status to update, the last payroll within the measurement period must be closed and the system date must be greater than both A) the pay date and B) the measurement period end date. Once these are met, the status will update in the nightly job.
How are the average hours calculated?
There is a lot of calculation that involves the average hours provided on the HCE Summary (i.e. Prorated hours - payrolls that fall within the measurement start and end date, number of payrolls that have been processed, earn codes marked for HCE, etc.). That being said, the basic calculation is as follow:
  • If eligibility is determined by Average hours per week, then: (total hours worked) / (pay days to date) * 7
  • If eligibility is determined by Average hours per month = (total hours worked) / (pay days to date) * 30
Why are some employees not showing average hours?
There is a lot of calculation that involves the average hours provided on the HCE Summary (i.e. Prorated hours - payrolls that fall within the measurement start and end date, number of payrolls that have been processed, earn codes marked for HCE, etc.). That being said, the basic calculation is as follow:
  • If eligibility is determined by Average hours per week, then: (total hours worked) / (pay days to date) * 7
  • If eligibility is determined by Average hours per month = (total hours worked) / (pay days to date) * 30
What if there is a break in service or an employee takes time off during the measurement period?
If an employee takes a LOA of any kind equal to or greater than 13 weeks, the admin should remove the employee and add them back to the group assuming they are rehired OR the last hire date is updated to a current date and not a date prior to their leave. Anything prior to 13 weeks does not qualify; however, the client has full control of changing the last hire date of the EE at their own will.
Does HCE hold audit?
Currently, there is no audit to see if anything was changed on any HCE tables. All HCE tables hold current data. Below are the HCE Tables for group and employee data.
How is the Administrative Period End calculated?
The Administrative Period END date can be calculated based off the Administrative period start date. The Administrative period start date = Measurement period end date + 1 day. In this example, a customer selects "End of the second month after measurement period".
  • Measurement Period End = 4/30
  • Administrative Period Start Date = Measurement Period End + 1 day = 05/01
Since the Administrative END date is being calculated based off the Administrative period start date, the end second month after the Admin Period Start would be 7/30.
  • End of month after = 05/30
  • End of First month after = 06/30
  • End of Second Month After = 07/30

PPACA Reporting Settings

PPACA Reporting Settings FAQs

Do the PPACA Reporting Settings need to be enabled by a system administrator or are they already available?
To view the new PPACA Reporting Settings page (System Configuration > System Settings > PPACA Reporting Settings) a system administrator must enable web access rights for applicable roles; this page is delivered OFF by default. Use the new page to define an applicable large employer (ALE) based on data from your organization's component companies or tax group.
What additional fees are incurred to handle PPACA reporting for our organization?
There are no additional fees, except the fees incurred if you choose to use UKG Pro Print Services.
What if you have multiple component companies in one FEIN?
You can configure your Applicable Large Employer (ALE) by Tax Groups or by Component Companies. Select the option that represents how your organization’s ALE has been configured in the UKG Pro solution. For more information about ALE Members, refer to the IRS’s Who is Required to Report FAQ document: http://www.irs.gov/Affordable-CareAct/Employers/Questions-and-Answers-on-Reporting-of-Offers-of-Health-Insurance-Coverage-by-EmployersSection-6056#Who
If we have one FEIN; but, 3 different offers of insurance, how do you determine the lowest premium?
You need to import this information for each employee and month. You may use the lowest of the options.
If we have two FEINs, do we have to file for both or can we just do all employees under 1?
Consult with your tax advisor on the appropriate reporting structure for your organization. The UKG Pro solution has been configured to support applicable large employers (ALEs) by component company or by tax groups.
What is the coverage stop date?
Check the Define Coverage Stop Date box to indicate whether to include the Coverage Stop Date in the calculation for the covered individuals and their coverage months, which are applicable to self-insured employers and reported on Form 1095-C, Part III.

1094-C

1094-C FAQs

Do we need one Form 1094-C per FEIN?
Yes, each Form 1094-C will be by FEIN. One Form 1094-C will be generated for each ALE that is configured using the ALE Members business rule.

1095-C

1095-C FAQs

Where can I find out more information about Forms 1094-C and 1095-C?
The IRS has published Q&As for both forms: Questions and Answers on Employer Shared Responsibility Provisions Under the Affordable Care Act
Could an employer be required to file for both Sections 6055 and 6056?
In cases where employers are self-insured, they must comply with both sections. This can be done via combined reporting by completing Form 1095-C, including Part III of the form, eliminating the need to report on the B forms (Section 6055).
Are the federal IRS forms finalized and available?
Yes, the federal forms are available online, here’s a link to Form 1095-C: About Form 1095-C, Employer-Provided Health Insurance Offer and Coverage
Is there a separate page to capture Parts I, II, and III?
Yes, the Offer of Coverage page is available in your UKG Pro solution at the employee level.
Will the information for Form 1095-C, Part II be maintained and downloaded from within our UKG Pro solution?
You will need to insert Part II information using the Offer of Coverage page or using the web import template.
How are Forms 1095-C populated?
We will be using information in your UKG Pro solution to populate Parts I and III. Part II will need to be provided by the customer via the Offer of Coverage page or using the web import template.
Will the Offer of Coverage page be populated from the employee’s record (medical coverage)?
No, you will need to manually enter or import this information.
Do we only list employees on Form 1095-C or do we list all persons having coverage (including dependents of the employee)?
For Part I, the employee is listed. For Part III, you complete if you are self-insured, and you list all persons having coverage associated with that employee (including spouse and dependents).
How does the information for dependents and beneficiaries get handled? Must this information be entered manually into our UKG Pro solution?
If you use the UKG Pro Benefits feature, your data should already be available and will be automatically generated to fill in Part III. If this information is not in your UKG Pro solution, you can import it using a web import template. Administrators will need to enter the Name, SSN, DOB information for dependents. The UKG Pro solution calculates the dependents coverage information that needs to be reported.
Part III is only for self-insured?
Yes, Part III of Form 1095-C is only for self-insured.
For Part III, do we list only those who elected coverage and not those who opted to waive our benefit?
Yes, for Part III, it is only those employees and associated spouse and dependents that are actually enrolled in coverage.
For self-insured employers, will the covered dependents be pulled from the current tables that store dependents information and their coverage?
Yes, as long as the information is stored in your UKG Pro solution; otherwise, employers will have to leverage the Import.
When we have multiple plans, both fully-insured and self-funded, with eligibility controlled by work location, how do we code individual employee records?
You will need to populate this per employee per month via the Offer of Coverage page or via the import.
For employers who are not self-insured, will their insurance company provide that information for covered dependents?
Yes.
Are the Forms 1095-C completed for all employees or only those that waived or did not participate in corporate plan?
All employees who work an average of 30 hours or more, regardless of whether they accept and enroll in coverage or not.
When is the individual form due to employees?
Form 1095-C is due Jan. 31 for the previous reporting year. Employees do not receive Form 1094-C.
What is the difference between Column B and C on Part III of Form 1094-C?
Column B is for full-time employees. Column C is the total number of employees, will include part-time, those in measurement groups.
How do you report employees who have declined benefits offered by employers?
You just need to report that the offer was made. On the 1095-C, on Line 16, you will report if the EE enrolled in coverage. If the employee declined coverage, you will likely use another code and the IRS should know that the employee declined the coverage.
Will 1095-Cs be distributed online via employee self-service?
Yes.
Will there be an option to include Form 1095-C with Form W-2?
No. They are separate processes and options.

Printing Versus Electronic Forms Distribution

Printing Versus Electronic Forms Distribution FAQs

Will this form be available in our UKG Pro solution?
We capture the needed information and the form can then be distributed to employees using a similar process as is used today with Forms W-2. In addition, Print Services will be available for customers who register for the service. A separate communication notifies customers when they can register.
What is the pricing for Print Services for Forms 1095-C and 1094-C?
$2 per form.
Can we provide both paperless (electronic) and printed forms?
Yes.
We print our Forms W-2 in-house; can we print Forms 1095-C and 1094-C in-house?
Yes, you can print these forms in-house.

Employee Consent

Employee Consent FAQs

Do employees have to consent or can we distribute electronic copies automatically?
Employees must provide their consent to receive electronic copies.
How will Form 1095-C be distributed to employees, a hard copy or electronically?
As a general rule, employers must provide a paper copy to employees. However, if employees provide their consent, then the employer can distribute the form electronically.
Is there an option available in our UKG Pro solution where an employee’s consent for electronic delivery can be recorded?
Yes, the employee consent option is available. For more information, refer to Configure the 1095-C Consent Form.
If Form W-2 is processed in a similar fashion, why does the employer need to receive employees consent to process forms electronically?
The law requires the consent for Offer of Healthcare Coverage to be handled separately.

Business Intelligence Reports

Business Intelligence Reports FAQs

What types of Business Intelligence reports are available?
The Business Intelligence reports that are available to verify data on IRS Forms, include:
  • PPACA 1094-C Summary
  • PPACA 1095-C Non-Employee Part I – Employee Info TEMPLATE
  • PPACA 1095-C Non-Employee Part II – Offer and Coverage TEMPLATE
  • PPACA 1095-C Non-Employee Part III – Covered Individuals TEMPLATE
  • PPACA 1095-C Non-Employee Summary
  • PPACA 1095-C Part II – Offer and Coverage Report TEMPLATE
  • PPACA 1095-C Part II Comparison
  • PPACA 1095-C Part III – Covered Individuals Report TEMPLATE
  • PPACA 1095-C Summary Report
If the pay history tables store employee hour information, why is there a need to create a Business Intelligence export that is used to import the 1095-C data?
The BI reports are used to help you determine who should be receiving a Form 1095-C. You can then leverage the BI report to populate the Import template to capture Part II of Form 1095-C, recording the employees’ offer of coverage, safe harbor and monthly premium. Employers do not need to use the Import template. Instead, they can track the same information on the employees’ offer of coverage page manually.

Non-Paid Employees (Terminated, Retired, COBRA Members)

Non-Paid Employees (Terminated, Retired, COBRA Members) FAQs

What about former employees? Are employers required to print and mail the form?
Yes, if employees were full-time during any month of the tax year, a Form 1095-C must be completed and provided to the former employees.
Would we need to track non-employee COBRA participants (ex-spouse, over-age children)?
Yes, non-employee’s (Cobra, Non-Employee Directors and Retirees) must also be tracked. An import is being created so you can import their data. If you are self-insured, you must complete Part III of Form 1095-C.
Will there be any import templates to report information for employees who are not in our UKG Pro solution, such as retirees who are still offered benefits?
Yes, a web import template is provided to support Cobra, non-employees, and retirees.
Will an import be created for COBRA enrollment information? If so, how will you handle the dependent only COBRA events?
The import allows for COBRA participants (including dependents).
Will Part III data be populated using data already in our UKG Pro solution, or should we manually export this information to a spreadsheet until we know the final format?
If the information needed for Part III is stored in the UKG Pro solution, it is populated if you are self-insured. However, if you do not store benefits and dependents information in your UKG Pro solution, an import template can be used to populate that information.
Is there a reporting requirement for individuals who are paying for coverage under COBRA that is still covered under the employers sponsored benefit program?
Yes, these individuals are required to be reported. The Import template is used to populate information for terminated employees who are under COBRA.
For terminated employees who elect medical COBRA coverage, is the employer responsible for reporting if they elect coverage under a self-insured plan?
Self-insured employers are responsible for reporting COBRA/retirees/non-employee directors. They can be reported in Part III of Form 1095-C.
When the Form 1095-C furnish paper copy for termed employees option is selected, will a paper copy be generated for all termed employees in the system or only for the employees who were termed last year?
A Form 1095-C is printed for any employee who was termed in a year in which they should receive a Form 1095-C.
Will paper copies of Forms 1095-C be generated for dependents and retirees?
Yes, paper copies are printed for non-employees since they will not have access to the UKG Pro solution.

Time Management

Time Management FAQs

We use UKG ProTime Management. Will our UKG Pro solution calculate each employee's status, month-to-month, or do we need to enter each and every employee, each and every month?
You must enter the reporting data. However, an import is available so you don't have to enter the information one employee at the time; the import enables you to upload multiple employees at once.
We use another vendor's time solution and then employee hours are imported into our UKG Pro solution on a weekly basis for payroll processing. Can our organization use all of the ACA features and services our UKG Pro solution offers, including the healthcare measurement groups, reporting for Forms 1095 and 1094, and leveraging the Business Intelligence reports?
Yes, as long as the payroll information is imported and all other necessary reporting information is entered into your UKG Pro solution, you can use all the ACA features.
What if your payroll hours are bi-weekly and you only import hours on a bi-weekly basis?
As long as all the hours are in your UKG Pro solution when it is time to generate the final forms, you should not have a problem with reporting.
Does UKG plan to provide UKG ProTime Management and UKG ProTime and Attendance customers with a solution to alleviate the need for an import for Form 1095-C data?
The offer of coverage information is not in your UKG Pro solution which is why we need employers to import it. 

UKG Pro Release Version

Release Version FAQs

Where can I confirm my UKG Pro release version number?
From your UKG Pro solution, navigate to the bottom right and select the 'i' icon to verify the version number. 

ACA Management, Distribution and E-Filing Services

ACA Management, Distribution and E-Filing Services FAQs

What types of Services does UKG provide?
UKG has a number of different services related to ACA, including printing forms, forms distribution and electronic filing. For more information, submit a case via the Customer Success Portal with “Affordable Care Act (ACA) Distribution and Management Services Assistance” as the description.

Part-Time Versus Full-Time

Part-Time Versus Full-Time FAQs

What about part-time employees who do not elect or are not eligible for insurance, do employers need to provide them with a form?
The offer of coverage is made to only those eligible employees who are considered full-time per IRS regulations. As an employer, you must provide an offer of health insurance and provide proof that you offered to use the form. Employees can select to not elect the plan you offer; but, you must offer it to eligible employees.
If we have separate sub-companies and FEINs, do we file under one umbrella company for benefits?
Consult your tax advisor to determine the appropriate reporting structure for your organization.
So part-time employees who are not electing insurance and are not eligible do not get a form 1095-C?
Yes, that is correct.
We offer part-time coverage that meets the mandate. Do we fill out Form 1095-C for those part-time employees enrolled in the part-time coverage since it meets their mandate?
If your company is self-insured, then yes. If your company is not self-insured, then you do not need to (your insurance company reports those part-time employees on the B forms).
How will the system know which is the lowest cost plan offered to the employee if your company has many rate structures by work site?
You may use the federal poverty line as one of the safe harbors to address this scenario.

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