Navigating ACA Reporting: Practical Insights for Sound Compliance

By: RPI Tech Connect   January 17, 2024

In this episode of RPI Tech Connect, Principal HCM Consultant Matt Slazak, walks us through the ins-and-outs of complying with the Affordable Care Act’s Employer Mandate. Even though the reporting portion of the law turns 10 this year, organizations continue to struggle. Matt shares first-hand experience in helping organizations meet the requirements and offers steps HR practitioners can take today to ensure compliance with the healthcare law.

Tune in to discover solutions for managing ACA compliance and reporting obligations.

Interested in listening to this episode on another streaming platform? Check out our directories.

Meet Today’s Guest, Matt Slazak

Matt Slazak is a Principal HCM Consultant with over two decades of experience in the Infor CloudSuite and Lawson environments, including more than ten years implementing and using the Talent Management/Global HR systems. He joined RPI in September 2016 and has successfully piloted, supported, and facilitated clients through strategic implementations and transformational process improvements.

Matt has managed diverse GHR system implementations and upgrades for clients in various industries and employee populations. In addition, he’s built hundreds of configuration changes and Process Flows, extending the use and abilities of the product to suit the system to the needs of the individual companies. 

Matt’s success in leadership, collaboration, and solution techniques has created lasting partnerships with clients and industry leaders. A frequent presenter at Inforum and many RPI webinars and Bootcamps, Matt is certified as a Global HR Consultant, Talent Planning Consultant, Compensation and Performance Consultant, Landmark Developer, and HR Payroll Associate. Additionally, he has a master’s degree in business administration, and has achieved SHRM-SCP and HRIP certifications.

Meet Your Host, Chris Arey

Chris Arey is an experienced B2B marketing professional with an extensive background in content creation, copywriting, SEO, website architecture, corporate branding, and social media. Beginning his career as an analyst before making a lateral move into marketing, he combines analytical thinking with creative flair—two fundamental principles required in marketing.

With a Bachelor’s degree in English and certifications from the Digital Marketing Institute and HubSpot, Chris has spearheaded impactful content marketing initiatives, participated in corporate re-branding efforts, and collaborated with celebrity influencers. He has also worked with award-winning PR professionals to create unique, compelling campaigns that drove brand recognition and revenue growth for his previous employers.

Chris’ versatility is highlighted by his experience working across different industries, including HR, Tech, SaaS, and Consulting.

About RPI Tech Connect

RPI Tech Connect is the go-to podcast for catching up on the dynamic world of Enterprise Resource Planning (ERP). Join us as we discuss the future of ERPs, covering everything from best practices and organizational change to seamless cloud migration and optimizing applications. Plus, we’ll share predictions and insights of what to expect in the future world of ERPs.

RPI Tech Connect delivers relevant, valuable information in a digestible format. Through candid, genuine conversations and stories from the world of consulting, we aim to provide actionable steps to help you elevate your organization’s ERP. Whether you’re a seasoned professional or new to the ERP scene, our podcast ensures you’re well-equipped for success.

Tune in as we explore tips and tricks in the field of ERP consulting each week and subscribe to RPI Tech Connect below:

Transcript

Chris (00:00)
In this episode, we’re joined by ACA compliance expert, Matt Slaszak. Join us as we discuss firsthand stories of troubleshooting common ACA challenges like ALE group formation, benefit selection, and employee measurements. Stick around and find out how InforGHR can assist.

Chris (00:02)
Welcome back. This is RPI Tech Connect, and I’m your host Chris Ari. Today, we’re going to be taking a look at new year responsibilities, specifically those around the Affordable Care Act. To help us navigate this complex area, we’ve got an industry pro joining us, Matt Slezak. Matt is a principal HCM consultant here at RPI. He’s helped dozens of organizations implement and troubleshoot ACA compliance processes. Matt, what else can you tell us?

Matt (00:31)
Well, first of all, thanks for having me on, Chris. Great to be here. Happy New Year to you. Yeah, you’re welcome. Yeah, I’ve been here at RPI now for about seven and a half, eight years, something like that, I’m not even sure anymore. Before that, I was an independent consultant for a while. And before that, I spent about 16 years at a local cancer research hospital up here in Buffalo, New York.

Chris (00:36)
Nothing.

Matt (01:00)
Um, so during that time, especially, I kind of cycled through every portion of HR that you can think of, um, including a good chunk of time, uh, working in the benefits department and a lot of time working on the HR IS side, uh, doing things like reporting. Um, so definitely, uh, kind of gone through the whole gauntlet in the HR world. Um, and here now, uh, very happy here.

And also looking forward to an upcoming lunch and learn session that we’ve got on ACA.

Chris (01:36)
Well, cool, man. Thanks for joining us and love to hear your background. That’s exactly the kind of experience I think folks need to fully understand ACA compliance and reporting and all the nuances associated with it. But like you said, we’re in 2024 now, which is the beginning of the 10th year of compliance with ACA, which is really kind of wild when you think about it. But even after a decade of practice…

I think businesses are still struggling with it. And so I’m curious, from your perspective, why is that? And what are the common areas that you see the most difficulty?

Matt (02:16)
Yeah, absolutely. Happy, happy 10th birthday to the ACA reporting, I guess. So yeah, it’s hard to believe that it’s 10 years past now. You know, think back to 10 years ago and, you know, the term ALE really just kind of meant something that you were cracking open on the weekend or something. But nowadays, the ALE groups are, you know, one is really causing the other one. Now it feels like

You know, we do see a lot of that in all seriousness, where there’s a lot of little details that you have to make sure that you have set up the right way. Not only in the info ERP space, but also just in general, you know, knowing how the ACA operates, knowing what your ALE groups really look like, making sure that your measurement periods are correct, making sure that you’re doing the employee measurements the right way.

making sure your benefit plans are set up the right way, making sure you’ve got things like your minimum coverage and making sure that you’ve got the affordability aspect taken care of. A lot of little nuances, a little checkboxes that we have to make sure are taken care of just to make sure that your ACA really is run the right way and making sure that you can get the reporting working out. If you don’t have things that are…

set up the right way, you’re never going to be able to produce a good report at the end of the year. Your 1095s are not going to look right, you know. You need to make sure that you have things set up and taking that time initially making sure that you’ve got those simple things set up the right way is going to pay big dividends at the end of the day. So you don’t have to kind of do everything manually. Just set it up the right way the first time and it’s going to help you out quite a bit.

Chris (04:02)
Yeah, a couple things that I want to dive into a little bit. And that first part is that, you know, it’s one thing to like set up your infrastructure correctly, but it’s another to like know that you need to do more than just making sure your measurement period is set up correctly and you’re selecting the right benefits plan and your ALA formations are correct. All that information is going to, you know, ultimately…

show itself on those annual 1095C reports. And like, if those aren’t reflective of what’s in your system, you’ve got something out of alignment there. But the other part of that is that, even though it’s 10 years later, you can almost understand and empathize with businesses because so many things actually change from year to year with ACA reporting, right? You’ve got the new affordability threshold, you have new codes being introduced, the instructions are different. And there was transition relief there for a while too.

Matt (04:36)
Mm-hmm.

Mm-hmm.

Chris (04:57)
I think that’s no longer on the table, right?

Matt (05:02)
Right, right. Yeah, I mean, the one thing that we can always say through the 10 years of ACA now, the more things change, the more they stay the same and vice versa. The more we think that we’re all stable, we’ve got 10 years of experience now, so we think we’re all set, but in all reality, it’s always changing a little bit. It’s always evolving a bit. So there are always different rates that we’re looking at and different

instructions that we have to kind of stay on top of. And I think one of the big takeaways that you always kind of want to make sure that you’ve got in line is you don’t want to be surprised by any of it. It’s not like they’ve just released something, you know, this week about how it’s going to be reported or anything or changing how it’s going to be reported. You know, stay on top of it. And if you stay on top of that and make sure that you’ve got your instructions in line and understand what they’re really telling you.

you’re going to be in a lot better spot. So, you know, that that’s definitely a good takeaway to try to stay on top of it as much as you can and stay in front of it.

Chris (06:07)
Nice. It sounds like maybe there’s some, you have some first-hand exposure there and seeing some companies struggle with it or lessons learned from the road of consulting. What can you, can you share something with us?

Matt (06:24)
Yeah, I’ve been through many, many roads down here. So yeah, you know, we were just kind of talking about it. My counterpart and I running that Lunch and Learn in a couple of weeks, Brad and I were chatting about it. And you know, we’ve seen some things where it’s not necessarily always the same, but we do see kind of variations on the same kind of theme where a lot of times people won’t…

Chris (06:26)
Hehehe

Matt (06:53)
be in front of these kinds of things and make sure that they have things set up the right way. So something as simple as, you know, making sure that you’ve got your benefit plans aligned and make sure that they’re out there and built the right way. Those are things that you can look at now. You don’t have to wait until the last minute. We’ve seen a lot of things even on implementation projects where, you know, we’ll have a mid-year go live, for example, and all of a sudden you’ve got…

Reporting coming from two different systems, you know, the payroll and benefits and information is in two different places. And we’ve seen a lot of that where we then have to get down to the end of year reporting and kind of try to tie it all together. You know, backfilling the employee information manually or running some loads through spreadsheet designer, you know, there are things we’ve seen, but it’s something where we can definitely get in front of it.

Chris (07:44)
Yeah.

Matt (07:49)
Try not to wait till the last minute on it.

Chris (07:52)
It seems like, and that’s a good example you bring up too, because when you’re doing an ERP implementation or migrations from an application to the cloud, you’re probably not thinking about ACA reporting that, right? You’ve got, it’s a much bigger project with lots of different priorities, and I’m sure that that’s probably something that, you know, maybe kind of falls by the wayside. But I’m curious though, what did that path look forward, like path forward look like?

Matt (08:05)
Mm-hmm.

Mm-hmm.

Yeah.

Chris (08:19)
with the company mid-year that had to transition.

Matt (08:23)
Yeah, it stumped definitely something, you know, we always have a credo when we’re doing these kinds of projects that you always have to start with the end in mind. And, you know, through many years of experience and through a lot of battle scars, I think we’ve kind of understood that as HR practitioners that we have to look at that and try to stay on top of it and definitely on the implementation side when we’re setting up these benefit plans. We’re looking at this from the

from the beginning. Like one of our first questions during discovery will be, what are your ACA plans? What do they look like? Let’s make sure we build these out the right way. And so we try to have that kind of at the forefront of our discovery and builds so that we’re ready for it. And we can actually run some of these tests mid-year and test that as part of our testing cycles.

But even if in lieu of that, if you haven’t done that yet, knowing that some of these things are going to be required, you know, we know that we’re gonna have to produce a 1095 and knowing that this is gonna come down the road, staying in front of it and getting used to it and understanding that, you know, if we see that we’ve got data from two different systems, let’s practice those loads now. Let’s make sure that we can see them and get in front of them.

just to make sure that we don’t have problems at the end of the year. We never want to be caught off guard at the beginning of the year. We know that we got to produce these forms. So let’s practice, let’s get used to them and let’s not be surprised when the system produces it in a certain way. Well, we can be ready for it. We can get in front of it.

Chris (09:54)
Mm-mm.

When you talk about these two different data pooling from two different systems, is it like employee hours and payroll in one and then benefits in another and reconciling those two? Is that right?

Matt (10:22)
Yeah, we’ve kind of seen it in a couple different ways. In that scenario where we’ll have payroll in one system and benefits sitting another, and other times we’ll have payroll and benefits sitting on one system, but we want to produce the reports from another. Just about every permutation you can think of is kind of what we’ve seen.

What’s more and more prevalent nowadays, especially with the in-for world is, you know, we still see a lot of people who are on the S3 payroll, for example, and knowing how to pull that data and put it into GHR so that we can produce our ACA reports from GHR. We’ve seen that a lot and we’re pretty used to it nowadays.

So again, we know that going into it, so we can start to prepare for that very early and get ready to test those loads out.

Chris (11:16)
Got it. And so curious, so we’ve kind of talked about, you know, some of the ACA horror stories during an implementation, but are there, is there anything that comes to mind from like a troubleshooting perspective where you had to go in and like fix something in a system, like if the measurements weren’t set up correctly or something like that?

Matt (11:26)
I’m gonna go.

Yeah, we definitely have seen that kind of changing the tire as we’re driving the car. We’ve seen that many times. And there are tools available for it where we can kind of make those changes manually or do loads on them to get that in. You know, it’s something that we’re familiar with. We’ve seen things where even not necessarily, it’s not always common, but

Chris (11:45)
I’m out.

Matt (12:07)
We have seen in a few places where it seems like the employee measurement should not be, you know, that big of a deal. Like we should understand that. But maybe we have people who have additional roles in the organization. And under, you know, ACA, we have to look at the sum total of this person and what hours are they working. And if somebody, for example, is working for a school district and we’re used to.

treating them as a teacher and that’s it. But yeah, they’re also teaching or they’re also coaching on the side or they’re running some continuing education on the side. So they’ve got additional work assignments. We have to stop and think, you know, is that going to be considered hours work for ACA purposes? And are we going over that 30 hour threshold at that point? You know, a couple different part-time positions inside the same organization.

In theory, that can make you ACA eligible. So we want to try to keep track of that upfront and really kind of get a handle on what our employees look like too. It seems like something very simple, but we’ve seen that a few places.

Chris (13:16)
Is it?

So two things there. I think what you’re referring to there, is that like the full-time equivalent count or like employees that may not look like they’re averaging full-time working hours actually are? And I think oftentimes people think that threshold is 40, but under the ACA it’s 30, yeah?

Matt (13:27)
Mm-hmm.

Right, right. Yep, you’re exactly right. That’s where we do see that happen every now and then, where we’re looking at somebody who we consider a part-timer, where their FTE hit is, you know, they’re at a 0.5 FTE. So in theory, they’re only working, you know, 20 hours a week, if we’re looking at a 40-hour work week. But if they’re doing those additional things, all of a sudden, that FTE hit, you have to look at the total FTE at that point.

And so we have to add that, you know, 20 that they’re working over here and the 10 that they’re working in this other role and the 10 that they’re working over here. Wow. Their total FTE really is, you know, 1.0 FTE and, or if they’ve crossed that 30 hour threshold, we’ve got to, we’ve got to make an offer for them.

Chris (14:21)
Yeah.

Yeah, and it seems like something that people just probably aren’t even thinking twice about, you know? It’s like, full-time or they’re not, it’s not that black and white. And not getting it right could be a really, really tough situation.

Matt (14:36)
Mm-hmm.

Right, right.

Yeah, yeah. I mean, the ACA, it’s not necessarily toothless anymore, but the huge penalties aren’t necessarily out there or as prevalent as they used to be. But it is still something where, I’ve heard somebody recently say to me, it’s something where, yeah, it looks like it could be wrong and we wouldn’t win in court on this. So we have to be ready for it. We want to be in front of it. We want to make sure we’re doing right.

Chris (15:06)
Ha ha

Matt (15:11)
not only by the letter of the law, but also for employees. At the end of the day, you know, I’m an HR professional and I care about my employees. I wanna make sure that they’re being treated the right way and they’re not being mistreated in any way at that point. We wanna make sure that they’re getting benefits if they’re entitled to them.

Chris (15:29)
Right. And so the benefits module in InforGHR, it has a way of kind of managing all these moving parts, right? How, could you tell us about that?

Matt (15:43)
Yeah, yeah. So there’s a few different simple components, I guess we would say to it. Not only is it, you know, something as simple as the benefit plan itself, you’re able to flag benefit plans and say that they are ACA applicable to the ACA. You’ve got places where we can define our ALA groups. We just have to…

make those definitions and really spell those out. So the GHR system is going to be able to handle that. It’s just, again, making sure that we’ve got our setups the right way. Same thing for our measurement periods, making sure that those are showing up the right way. There, the system can handle a lot of that automatically as long as we build some parameters on it. But it comes back to define what your employees really look like. If you know that you’ve got to look at, you know,

multiple work assignments for people be ready for it. And we can define the system or have the system define it the right way and really look at it and make sure it’s somebody as whole.

Chris (16:45)
Yeah.

Got it. It sounds like the more time you spend on the application upfront, the better off you’re going to be. Because you’ve spent the time to set up those parameters, like you mentioned, upfront. And you’re not going back, you’re not fixing things, you’re not scratching your head being, is this person really full time? You just know. Is that right?

Matt (16:56)
Mm-hmm.

Right.

Mm hmm. Exactly, exactly. Yeah, there’s no reason why this has to be a surprise for any of us. You know, it’s not like ACA is brand new and they just popped this requirement on us the first week of January and we have to report on it by April. We know it’s out there. You know, let’s not ruin our holidays on it.

Um, you know, Brad was saying that to me the other day is like, you know, we meet, we want to allot time to focus on this in June and July so that we don’t ruin our holidays. You know, there’s no reason somebody has to like lose their Christmas and new years because they’ve they’re preparing for ACA reports or anything. Um, you know, get in front of it and you’re going to be okay.

Chris (17:42)
Yeah.

Like

The ACA is the Grinch who stole Christmas. Yeah.

Matt (17:57)
Hopefully not. So that’s what we want to try to avoid. There’s no reason why we can’t avoid that.

Chris (18:03)
Cool. Well, we’re getting close to the end of today’s segment, but before we wrap up, I wanted to ask you one last thing, and it’s this. If you could offer today’s audience one piece of advice with regard to ACA compliance and reporting, what would it be? I feel like I know the answer, but I want to hear it.

Matt (18:24)
It sure sure. Yeah, you probably could say it with me at this point, but yeah, definitely take your time. Get in front of it like we know that it’s out there. Stay in front of it. Get in front of it. It’s not a surprise. So take your time. Make sure things are set up the right way. And if you’re confused about where some things are or how to set it up the right way, you know, that’s definitely something we can help you with. Um, but just don’t

Don’t wait on it. You know, it’s not a surprise. We can get through it and get through it earlier and not be stressed out about it all.

Chris (19:00)
And is this the kind of stuff that you’re going to be talking about in the lunch and learning a couple weeks?

Matt (19:06)
Absolutely, yep. We’re going to take people through and they’ll get some hands-on experience with it. We’ll be playing in our sandbox and you know actually going through and actually looking at these screens and touching them and hopefully being able to produce a few reports. We’ve got some limitations in our sandbox but you know we want people to go and get familiar with those screens and actually work with them and understand what they can actually do.

Chris (19:31)
Awesome. Well, thanks for sharing that with us, Matt. And for those of you listening, Matt’s gonna be hosting a virtual training session on ACA reporting and compliance January 26th at 11 a.m. It’s a four hour session if you’re interested. If you need a refresher on the requirements or how to use Infor applications to manage reporting, we invite you to check it out. If you’re interested in attending or have a question about today’s episode, contact us at.

podcast at rpic.com again, that’s podcast at rpic.com. Thanks again.

Matt (20:09)
Thank you very much, Chris.

Chris (20:10)
Alrighty, we’ll talk to you later, Matt. Thank you.

Matt (20:12)
Alright, take care.