Health Care Reform Reporting requirements (ACA)

[jwiblepasshe22]

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.

[Former Member · Accepted solution]

Folk

I have implemented all 4 notes and our SAP HR version is 86 but i still cannot see the Affordable Heath Care link in SPRO as mention in guide.

I have done all pre /post implementation step mention for each note.

Please advise how can i see this link in SPRO

Thanks

[Matt_Fraser · Accepted solution]

Andy, if I recall correctly, the IMG nodes in SPRO do not show up from the Notes, only from applying the HRSP (92). After applying the Notes, you will need to use SM30 and call the customizing views directly to achieve the same result. A while back Jeff Wible posted a "cheat sheet" for configuration that detailed what those views are, and I think that might also be documented in some other more "official" documentation. I can't recall if Jeff's guide was attached to a comment earlier in this thread or if it was to a comment in the ACA thread that Graziela started, but it's back there.

Cheers,

Matt

[nomad · Accepted solution]

Just as a side comment to Matt....

The SPRO links show up in HRSP (91) as (92) is not out yet.

We implemented Option #2 (which included the latest SP up til now) and SPRO is populated with ACA.

Again just FYI

-Chris

[jwiblepasshe22 · Accepted solution]

Matt is correct, the updated "User Guide" was released yesterday and is attached to the original "Announcement" OSS note #2060131 (at the bottom of the note). I'd attach it but for some reason .PDF and other common document types are not acceptable for this site?....

[Former Member · Accepted solution]

Thanks Matt we are on EHP 6 ERP 6.0  and to go this level and above i believe i have to upgrade entire stack. Correct ?.

https://websmp103.sap-ag.de/~sapidb/012002523100011071992014E/SAP_HREnhP604EA-HREnhP606.htm

AP_HR EnhP6.04 EA-HR EnhP 606

87 49

14.05.2015

14.05.2015

EhP.Pck 6.06 STACK 11 (04/2014)

[Matt_Fraser · Accepted solution]

You need Stack 11 for ERP 606 as a minimum to support SAP_HR 6.04 sp91, per the chart, yes.

[Former Member]

Thanks a lot Jeff. I really appreciate your help. 🙂

[Former Member]

Hi All,

       I have a few questions on the SAP notes implementation inorder to facilitate the ACA Benefits reporting to the IRS. I ned your help on this please.

1. Once the SAP Notes are implemented, do we need to do any configuration steps inorder to meet the requirement?

2. Does SAP facilitate any additional infotypes where we can store the Employer details and the EIN number?

3. How does the output look like? Do we need to execute any program to extract the output from SAP?

4. On which forms do the employer need to report to the IRS? Is it only 1094-C and 1095-C as per my knowledge?

Please clarify..

Thanks in Advance

Regards,

Satish

[jwiblepasshe22]

Satish, the answers to your questions are contained as part of OSS note 2167502. There are several attachments to that note that outline both pre and post configuration requirements as well as a User guide.

[nomad]

Jeff/All,

Just FYI I added this comment over at the main thread now - as it seems most are still looking here for answers too.

So it seems that apply the notes early is causing issues/incomplete.

When will ALL the ACA notes/forms/documents/features be included in Support Packs?

In the previous thread it was mentioned September 10th is this still the case?

Should most wait until the WebCast on the 17th or is that not technical/install related?

Hope they respond ASAP....

-Chris

[jwiblepasshe22]

Chris,

This is what I received directly from SAP as far as their immediate plans for the ACA functionality:

Additional information:

For the most up-to-date information on SAP ERP HCM US Benefits Management, please see http://service.sap.com/hrusa: SAP Note 2060131 has been updated with the numbers of the SAP Notes that deliver the functionality for Information Reporting for Employer Sponsored Coverage and Minimum Essential Coverage. Please refer to the References section of the Note.

ASUG Webcast: Affordable Healthcare Act (ACA) - Review of SAP’s solution for Information Reporting for Employer Sponsored Coverage and Minimum Essential Coverage Requirements is currently scheduled for Thursday, September 17, 2015 10am PST (please register via ASUG event page)

Roadmap: Due to the recent release of IRS publication 5165 Guide for Electronically Filing Affordable Care Act (ACA) Information Returns (AIR) for Software Developers and Transmitters on August 18, 2015 and the pending release of the final 1094 and 1095 forms and instructions for 2015,

SAP is planning the following delivery schedule to address upcoming legal changes and corrections for Information Reporting for Employer Sponsored Coverage and Minimum Essential Coverage:

General Availability            SAP note 2167502            Released on August 28 o 1st SAP ACA Note Update

SAP Note 2211233           Planned for week of September 21, 2015 o 2nd SAP ACA Note Update

SAP Note 2211234           Planned for week of October 12, 2015 o 3rd SAP ACA Note Update

SAP Note 2211235           Planned for week of November 16, 2015 o Electronic Filing SAP ACA Update

SAP Note 2211236           Scheduled for December 2015 CLC, planned to be available on December 10, 2015

[paynea]

Hi all, we have all the notes installed.  The last one was a doozy.  I was wondering if anyone else has applied them and having any issues?  I am unable to see the new folder called Affordable Care Act under health plans in configuration.  Does anyone else see it?

[joelle_wilson]

Angela, we do have notes installed as of today.    It's my understanding that because we are installing these notes individually (not part of a larger support pack stack) we will not see the Affordable Care Act directory.   We've found that you can access the newly installed contact through direct table entries, not through SPRO.    

[jwiblepasshe22]

FYI, we had the same understanding and did the config by table names through SM30 as well.

[paynea]

Has anyone had any luck with configuring the features? There is no documentation attached to guide.

[jwiblepasshe22]

You are correct and we had asked for them to be added....

Currently, there very few instructions and a list of the return values, but you really need to know the rules of the forms in order to set up the features.

Example for feature UBABC – ACA B\C Form Generation

You would need to know that the c-form is for the employer data (Part II) and active employees enrolled in self-insured plans (Part II).  But for retirees, even if they are in a self-insured plan, would get a b-form.  This type of instruction is not in the features. I'll mention this deficiency again to the product manager. Also, please post it at the other thread as well:  http://scn.sap.com/thread/3792418

[jwiblepasshe22]

All, since SAP Note 2167502 – BEN: Main Note – Affordable Care Act (ACA) was released as planned on August 28, 2015, SAP has created a new thread to use if you have any questions on the SAP functionality for Information Reporting for Employer Sponsored Coverage and Minimum Essential Coverage. Please post your questions on http://scn.sap.com/thread/3792418

Additional information: • For the most up-to-date information on SAP ERP HCM US Benefits Management, please see http://service.sap.com/hrusa: SAP Note 2060131 has been updated with the numbers of the SAP Notes that deliver the functionality for Information Reporting for Employer Sponsored Coverage and Minimum Essential Coverage. Please refer to the References section of the Note. • ASUG Webcast: Affordable Healthcare Act (ACA) - Review of SAP’s solution for Information Reporting for Employer Sponsored Coverage and Minimum Essential Coverage Requirements is currently scheduled for Thursday, September 17, 2015 10am PST (please register via ASUG event page) • Roadmap: Due to the recent release of IRS publication 5165 Guide for Electronically Filing Affordable Care Act (ACA) Information Returns (AIR) for Software Developers and Transmitters on August 18, 2015 and the pending release of the final 1094 and 1095 forms and instructions for 2015, SAP is planning the following delivery schedule to address upcoming legal changes and corrections for Information Reporting for Employer Sponsored Coverage and Minimum Essential Coverage: o General Availability                                        SAP note 2167502            Released on August 28 o 1st SAP ACA Note Update                            SAP Note 2211233          Planned for week of September 21, 2015 o 2nd SAP ACA Note Update                          SAP Note 2211234          Planned for week of October 12, 2015 o 3rd SAP ACA Note Update                          SAP Note 2211235          Planned for week of November 16, 2015 o Electronic Filing SAP ACA Update              SAP Note 2211236          Scheduled for December 2015 CLC, planned to be available on December 10, 2015

[jwiblepasshe22]

All, sorry for the delay but we didn't receive notification until late Friday evening that the OSS note 2167502 has been released for general availability. I have attached the note for reference, be sure to also download and carefully follow the User Guide and the Pre/Post implementation step documents that are attached to the note.

Thanks,

Jeff Wible

2167502.BEN.Main Note - Affordable Care Act.txt.zip

[paynea]

Thank you!  We are trying to apply the first note 2208461 and after we apply we are trying to do the manual steps but when we go into SA38 and try to run RPU_PAYUS_UDO_NOTE_2208461 it says the program does not exist.  Is there an additional note we need?

[joelle_wilson]

Angela, we also encountered this error this morning.   The program name should read RPU_BENUS_UDO_NOTE_2208461, we believe the 'PAY" is a typo.

Unfortunately after passing this hurdle we've found the last step for running this program fails saying we don't have authorization to overwrite the SAP entry.    We have opened an OSS message asking for assistance and will let the group know what we learn.

[jwiblepasshe22]

Joelle, thanks for the update, we had numerous issues during the pilot testing and SAP had revised the User Guide based on feedback but these issues must have been missed...

[Former Member]

Jeff... we outsource our Benefits so we do not have the Benefits infotypes configured.   Instead, we receive a feed of the employee Benefit deductions and they are stored on infotype 0014.   The Benefits provider will send us any additional employee data that we need for these ACA forms, but I do not see anything in the User Guide which instructs on what to do if your Benefits is outsourced, unless I missed it.    Is there an additional document for this with instructions?

Thanks,

Linda

[jwiblepasshe22]

Linda, I know a program to load data into the new ACA database was discussed but I do not recall any resolution. I suggest sending an OSS note to SAP.

Thanks,

Jeff

[joelle_wilson]

We're making small steps here!  We were able to bypass the authorization error by having BASIS run the program.

[paynea]

Have you been able to get all notes:  SAP is shonig that OSS note 2211080 and 2167502 are not released. 

[joelle_wilson]

Angela, I feel like we are working on this together 😃    Our BASIS team discovered that SAP Note 2167502 is available with a new version.  A lot of updates this morning!

[paynea]

I am just thankful we all have each other for this!

[former_member52740]

From what I understand, if you have outsourced benefits then they should be able to create the year end reports for company and employee. From what you explained they already have your employee HRIS/beenfits data and they are the  source of truth for benefits information. It is better to create the reports. All you have to do additionally send is to configure & send the Define address of Applicable large employers so they can complete the reporting for you and send it. This will be much easier.

[former_member52740]

Sorry I just clicked send while I was editing. Also I scrolled up and just saw your earlier note on Aug 13th, stating  that your 3rd party vendor will take months to develop a report. I think SAP also will take few months to come up with one and followed by fixes. If the vendor can retrive information for the report they should be able to create the report / forms too. So give a try with the vendor and see they can do this since they have all the info required.

[joelle_wilson]

Michigan State University is also waiting patiently (?) for this development.   Would love an update too!

[nomad]

Jeff/All,

Still no info released as of yet, today 8/28

Do you know if SAP is delaying again?

-Chris

[jwiblepasshe22]

Chris, not that I am aware but I will follow up with them now and let you know if I hear of any changes.

[paynea]

Please let us know as well.  We are waiting for this.

[jwiblepasshe22]

OSS Note 2060131 has been updated with more details on the planned new programs, configuration view, forms etc. that are planned to be available for general delivery in September.

[Maggie3654]

Jeff,

Will the note be part of a support pack or will the users be able to implement/apply the note separately?

Regards,

Margaret Walter

[jwiblepasshe22]

Margaret, the plan at this point is to provide the solution via OSS notes first by the end of August and then also as part of September 10 CLC/HRSP. –Note: Subject to change since final instructions for XML, corrections, and 2015 forms have not been released

[Former Member]

Jeff... I apologize if this has already been answered, but we outsource Benefits processing to a 3rd party.   It mentions in OSS note 2060131 that a custom SAP program may have to be developed for this for updating the new SAP database tables for the forms.   When will the OSS note be updated with the custom program details and instructions, i.e. for the abap classes, new database tables, etc. ?   Our 3rd party vendor needs several months lead time and needs to know the format for which they need to send any data to us, etc.   Will this also be provided at the end of August?

[jwiblepasshe22]

Linda, they are planning on releasing the OSS notes and a User guide with additional information on for general availability on 8/28 at this point.

Thanks,

Jeff

[DawnStephans]

We are also waiting to see what SAP is going to provide for the ACA reporting requirements.  At this time we have not planned to do anything in-house with the hopes and expectations that SAP will provide the legally required reports.  I'm not sure if there is something that we could/should be doing at this point, just in case.

What is everyone else doing, if anything, for a contingency plan?

[jwiblepasshe22]

Dawn,

We and several other companies are working with SAP on these requirements. We have a meeting with them tomorrow and are supposed to begin testing the solution soon. Unfortunately we are not yet permitted to divulge any details but I will say that the solution incorporates standard SAP Benefits and Payroll Infotypes to produce the required reports. Please also refer to OSS notes 1910650 (FAQ) and 2060131 for further information.

We will update this string ASAP with details as soon as they are available to release.

Regards,

Jeff Wible ASUG HCM Community Facilitator Director, SAP Human Capital Management Systems Shared Administrative Systems Pennsylvania State System of Higher Education 2300 Vartan Way, Suite 207 Harrisburg, PA 17110-9720 Phone: (717) 703-5435 Fax: (717) 703-5444

[Former Member]

Jeff,

Is there any update from your meeting with SAP ?

Appreciate all your effort on this topic.

[jwiblepasshe22]

Yes, we are currently working with SAP on some pilot testing. SAP's plan at this point if all goes well is to have a call with US customers some time in August. As soon as we get through the pilot testing more specific information will be available.

[Former Member]

Information is really adequate .

Hope ,this is the combination of customization of a program and custom infotypes.

If the program is there then what type of integration between a custom infotypes & program.

Because, SAP standard doesn't satisfy the requirement as i feel. May be this quarter or next quarter they may comeup with.

When we create a custom infotype what are all the fields need to be incorporated because,  i also having similar requirement like section 6055 & 6056 reporting. Actually, for ex. year 2015 & 2016 will be required 2 tax forms hopefully. Form 1094C & 1095C are employer and employee prospective.

So can you please extend your kind coordination on it.

will be really appreciated for any helpful answers or materials or FS's etc.

Thanks & Regards

Samuel.

[jwiblepasshe22]

Per SAP's product manager for this requirement they are currently in the process of developing functionality with the August 2015 delivery date as a target. I have attached some information we have shared with SAP as to how we have interpreted the requirements and the custom development we have already done in our system. We are hopeful that they will at least provide a viable way to produce the required reports.

Regards,

Jeff Wible

[Former Member]

Thank you for the information.  Your approach is very similar to ours.  We created a custom infotype in which we populate with our measurement program output.  We not only add the ACA flag (measured eligible or ineligible) but the details of the particular measurement (hours, days in measurement period, qualified LOA during measurement, days separated during measurement, average, etc).  This allows our users to query the information and also allows our enrollment call center to answer questions as to why an employee was deemed ACA eligible or ineligible.  Our eligiblity logic then checks this infotype and does an override for those in an ineligible status but who measured ACA eligible.  So far all is working well. 

We too plan to create the reporting and forms in house. I hope that SAP takes your information into consideration and makes their product flexible enough to handle various approaches.

[Former Member]

Information is really adequate .

Hope ,this is the combination of customization of a program and custom infotypes.

If the program is there then what type of integration between a custom infotypes & program.

Because, SAP standard doesn't satisfy the requirement as i feel. May be this quarter or next quarter they may comeup with.

When we create a custom infotype what are all the fields need to be incorporated because,  i also having similar requirement like section 6055 & 6056 reporting. Actually, for ex. year 2015 & 2016 will be required 2 tax forms hopefully. Form 1094C & 1095C are employer and employee prospective.

So can you please extend your kind coordination on it.

will be really appreciated for any helpful answers or materials or FS's etc.

Thanks & Regards

Samuel.

[Former Member]

Hi Debra,

         We have cetain system constraints due to which we were unable to implement SAP provided solution for ACA Benefits. Our client is asking for custom development in this regard. I have no clue how to provide a low level design to my ABAPer to do the development. Can you provide a document or some valuable inputs on how to proceed further? Also, let me know approx how much time it might take if we do a custom development.

Your help is greatly appreciated!!

Regards,

Satish

[former_member52740]

Hello:

Can any one please tell if we have benefits administration with Aon Hewiit and not storing the health coverage with in SAP (IT 0167), is it still possible for us to generate the report using the proposed SAP's standard delivery?

What are the options for employers who have outsourced beenfits?

Thanks Raj

[Former Member]

We are in a similar situation.  Currently, I think our TPA is working to provide the required reporting.

[paynea]

Hi all,  We are also in need to report the following forms to the IRS but cannot find in SAP.  Please let us know if SAP will incorporate these.

1094-C

1095-B

1095-C

Thanks!

[jwiblepasshe22]

Angela,

Please refer to previous message regarding OSS note 2060131, which SAP released as an "Informational" note explaining their plans to address these requirements.

Thank,

Jeff

[paynea]

Does anyone know then what fields, infotypes SAP will use to generate the reports they are going to deliver in August 2015?  The note does not display that. 

[Former Member]

We reached out to SAP about 18 months ago to discuss the entire Healthcare Reform measurement process, reporting, eligibility, etc.  At that time SAP disagreed with our legal counsel's interpretation of the requirements (I'm not sure of their opinion today).  We have customized the entire process to this point to be ready for our first required Measurement in October 2014 with a Stability period beginning 01/01/2015.  This has all been extremely time consuming.  I would love a little bit of a break and have some SAP delivered reports!  I will also be starting work soon on the COBRA change for employees coming to the end of a Healthcare Reform eligible stability period.  A COBRA event from SAP would be much appreciated.

Thanks!

[jwiblepasshe22]

As an update on this topic, SAP has released OSS note 2060131 - Announcement Note for Information Reporting for Employer Sponsored Coverage and Minimum Essential Coverage. Below is a copy of their "Solution" contained in the OSS note. Though no details are provided at this time, it appears SAP may deliver a solution for US customers sometime in 2015:

Solution

l Currently, the first filing is due in the first quarter of 2016. The planned delivery date of this legal change can be found in the Other Attributes

section. For more information about the released solution and how to implement it, see the Reference to related Notes section. Note that this

section will only be updated after the solution is released.

l The planned delivery for this new legal change includes a new report with ALV output, PDF interface, and PDF form templates that will

provide customers with the flexibility to implement forms based on their reporting requirements. Employee Self Service is not in the scope of

this delivery.

l The planned delivery for this new legal change is subject to change based on final forms, instructions, rules, and regulations.

l The planned delivery date can only be met if the legislative procedure, including the rules and regulations, is completed or updated in time.

[Maggie3654]

Our Sr Attorney just notified us that the IRS has released draft instructions for the health care reform employer reports.

Regards,

Margaret Walter

[Former Member]

Correct to assume (from reading the SAP note) that the SAP solution requires using Benefits module?

[jwiblepasshe22]

Chad, that is probably a safe assumption. We are currently working with them on the design phase of this and hopefully will have more information by early this summer.

[Former Member]

Is there any update you can share on what will be delivered from SAP to handle the reporting requirements and forms?

[jwiblepasshe22]

Yes, OSS Note 2060131 (attached) has been updated with more details on the planned new programs, configuration view, forms etc. that are planned to be available for general delivery in September.

[Former Member]

Does SAP plan to deliver a solution where the reports can be pushed to ESS similar to a W2?  I saw in the note it says ESS is not in the scope of this delivery but I wasn't sure if that was also being worked on or would be a future enhancement.  Thank you!

[jwiblepasshe22]

Angie, as the note indicates, ESS is not in scope for 2015 reporting but we have asked that it be added sometime in 2016. Hopefully SAP will be able to accommodate this request.

[jwiblepasshe22]

Per the SAP product managers guidance we have created OSS incident number 792469 2014 to document the requirements for the 1094-C and 1095-C forms.

Also, attached is the detailed specifications document we created for this issue as well.

[Maggie3654]

I too agree that this would be very time consuming for each company to do via custom development when it is definitely something that each and every company will have to comply with.  We agree and would expect that for this legal reporting SAP should provide as a standard.

[Former Member]

We have really just became aware of the new set of requirements after they were delayed last year.  We are considering the need for custom development but agree that this would be very time consuming for something that every company will have to comply with.  We agree this legal reporting should be provided as standard by SAP.

[jwiblepasshe22]

Thank you Chad. We are going to be submitting our OSS note with some specific "specs" based on the 7/24/14 release of the IRS requirements for forms 1094 and 1095. I will copy the details of our note in this chain as well.

Here is the link to the requirements:

http://apps.irs.gov/app/picklist/list/draftTaxForms.html;jsessionid=7gZEn0s-FLS23-Tr3eiy-g__?value=1...