Angela, Below is the Incident we filed on this topic to SAP, in summary, we have asked SAP to provide a “switch” or indicator to select one or two forms. Based on our interpretation of the IRS referenced below, there should only be one form generated in these cases.
Incident # 829823/2015
Latest response from SAP: 10/16/2015 - 17:53:25 EST - Info for Customer by SAP Hi Agnes,
This is to let you know we partially released this correction on SAP Note 2211234. Currently the system is only printing forms for Employees which were in one of the following categories for at least one month: - Full Time - Part Time Enrolled - Non Employee Enrolled However we are taking your feedback into consideration and plan to release the additional correction, to generate forms for all EE that were on the categories above for at least one day. We plan to release this on 3rd ACA Update Note.
Incident description:
Short Text
Logic for ACA Features UBAIC and UBAB
Long Text SAP Incident –
Logic for ACA Features UBAIC and UBABC Date: October 1, 2015 Within the features, I am still having an issue with trying to get the correct IRS required form for employees and non-employees. Below is the criteria that require a form to be printed. The criteria needs to be applied in the order listed so the correct form is printed and only one form. Once a PRNR matches the criteria, the logic stops and that form is printed. Logic for an employer to produce a form:
1. The PRNR was an active employee and designated as being ACA FT at any time within the selection period – this will be a C-form
2. The PRNR was an active employee, and designated as being ACA PT, and enrolled in a self-insured plan at any time within the selection period – this will be a C-form
3. The PRNR was a non-active employee or a non-employee enrolled, and in a self-insured plan at any time within the selection period - this will be a B-form
4. All other PRNR’s – no form required by the IRS IRS Question and Answer for and employer using a B-form. It states that a B-form can only be used for a non-employee if they were a non-employee for the entire year. Therefore an employee that retired mid-year, cannot receive a C-form and a B-form.
http://www.irs.gov/Affordable-Care-Act/Employers/Questions-and-Answers- about-Information-Reporting-by-Employers-on-Form-1094-C-and-Form-1095-C:
10. How should an employer report enrollment information for self-insured coverage provided to an individual who was not an employee on any day of the calendar year, such as a non-employee COBRA beneficiary (for example, the former spouse of an employee), member of the board of directors, or retired employee?
An employer that sponsors a self-insured health plan may report enrollment information for individuals who were not employees on any day of the calendar year by entering code 1G, Offer of coverage to employee who was not a full-time employee for any month of the calendar year, on line 14 of Part II of Form 1095-C for all twelve months and completing Part III of Form 1095-C. (Note, however, that Form 1095-C requires the recipient’s Social Security number (SSN) on line 2 in all instances, so Form 1095-C cannot be used for covered individuals who have not provided a SSN to the employer regardless of whether the employer has requested the information.) Such individuals might include a non-employee director, a terminated employee receiving COBRA coverage who terminated employment in a previous calendar year, a retired employee who terminated employment in a previous calendar year, or a family member (including a surviving spouse or dependent) of such an individual if the family member is receiving coverage independent of the individual, such as by electing individual COBRA continuation coverage. All family members of the individual who are covered individuals due to that individual’s enrollment (for instance, a spouse of a retiree who is enrolled in the plan because the retiree elected self plus spousal coverage) should be included on the same Form 1095-C as the individual who enrolls in the coverage. For the ability to use Form 1095-B as an alternative to Form 1095-C for an individual who was not an employee on any day of the calendar year, see the instructions for Forms 1094-C and 1095-C.
In discussions – it was found that the field ESTAT was no available in feature UBABC. Also, the self-insured plans would need to be added to feature UBABC in order to limit the B-form from being printed for all other PTE employees and non-employees.
Steps for Reconstruction
Logic for an employer to produce a form: 1. The PRNR was an active employee and designated as being ACA FT at any time within the selection period – this will be a C-form 2. The PRNR was an active employee, and designated as being ACA PT, and enrolled in a self-insured plan at any time within the selection period – this will be a C-form 3. The PRNR was a non-active employee or a non-employee enrolled, and in a self-insured plan at any time within the selection period - this will be a B-form 4. All other PRNR’s – no form required by the IRS Error Message Number Screen Number Tran