Top 10 ACA FAQs

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Top Questions and Answers Asked About the
Affordable Care Act (ACA)

Q: Does PPACA require all employees to be tracked or only those not currently meeting the full-time employee threshold?
A: 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 UltiPro to identify employees who are eligible for the offer of coverage. You must 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 2015.

Q: Is the minimum cost required to be filled in even if they are not covered?
A: 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.

Q: Do we need to track offer of coverage information for each employee?
A: Yes, you need to track this information for each employee. IRS reporting requires you to include all employees who were offered or should have been offered health insurance coverage.

Q: If an employer chooses to offer benefits to all full-time and part-time staff, does the employer still need to track all the monthly time data for IRS reporting?
A: You need to track which employees are considered full-time based on IRS requirements. For each full-time employee, track the type of offer of coverage (using the associated offer of coverage code) that was made to fulltime employees for each month during 2015. If you are a self-insured employer and offered part-time staff coverage, complete Part III of Form 1095-C for employees who accepted coverage.

Q: Is it the responsibility of the employer or the insurance company to gather employee and dependents’ social security numbers when submitting the required reports?
A: If you are filing as an employer, you need to gather the employee and dependents information.

Q: Is a non-profit organization that is self-insured subject to reporting?
A: If you have 50 or more full-time or full-time equivalent employees, then, yes, you are subject to reporting.

Q: 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?
A: 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.

Q: Would we need to track non-employee COBRA participants (ex-source, over-age children)?
A: Yes, if you are self-insured.

Q: If you have union employees covered by a union health plan, must they be reported as well?
A: Employers must offer health coverage to all eligible full-time employees who meet the IRS requirement, regardless of membership in a union.

Q: Will employees be required to auto-enroll new full-time employees in a health plan?
A: The ACA originally required applicable employers to auto enroll new full-time employees in a health coverage plan offered by the employer and to continue enrollment of current employees in an offered health plan. However, this provision never went into effect as regulations for implementation were still being ironed out.

As of November 2015, employers no longer have to worry about the provision requiring auto-enrollment. The Bipartisan Budget Act of 2015 repealed the auto-enrollment mandate.