BN991 Release - COBRA/Retiree Processing

We just applied the latest release that included the BN991 for COBRA/Retiree processing. This does not pick up any data when I run it and I do not know where I can actually add in the COBRA information so that the BN991 will pick it up. Do we have to load in the COBRA/Retiree data via the BN597, or is there another way to do this, OR am I jumping ahead and the last pieces to process COBRA/Retirees still have not been delivered?

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sriman-shivakoti

BN597 loads resources, which could be different that COBRA participants or could the the way you will need to manage your COBRA participants.

Based on KB1679901, I believe BN991 will process from BN7X forms. Those forms don't work for us for several reasons.

From KB 1679901 on the BN991....

Q: What is the processing logic for the ACA COBRA/Retirees IRS Codes (BN991)?

A: You will run BN991 in your ACA processing cycle if your organization has COBRA/Retiree enrollments in self-insured health plans as indicated on ACA Plan Details (BN15.3). The primary purpose of BN991 is to generate the data for reporting Part III Covered Individuals. The BN991 processes based on COBRA/Retiree HL enrollments in BN71 (COBRA Benefit Entry) or BN72 (Retiree Benefit Entry).

COBRA overview:

A COBRA participant can be 1) an employee (HR11), or 2) a spouse/dependent of the employee (BN70 participant record only).
Enrollment in ACA HL plan on BN71.

Retiree overview:

A retiree must have an HR11 record.
Enrollment in ACA HL plan on BN72.

The BN991 will typically be run after the run of BN990 (BN990 is run to create the 1095 data based on the BN32 enrollments/offers for an employee’s active months).

BN991 will update or create the data for reporting 1095-C:

Part I - created for employees who were terminated in the prior year with COBRA or Retiree enrollments in the reporting year
Part II – 1) updated for active employees on COBRA (individuals offered coverage due to a reduction in hours making them ineligible for standard health coverage) or 2) created for employees terminated in prior year on COBRA
Part III – created or updated to report COBRA/Retiree coverage by month for each covered individual (employee/participant and dependents)

BN991 processing logic depends on the type of COBRA scenario (terminated current year, terminated prior year, employee with reduced hours, or retirees). See examples below:

Terminated Employee who has worked in the reporting year and elected COBRA coverage (with two dependents).

Example (COBRA):

Employee offered and enrolled in HL benefit coverage from January – June (BN32)
Terminated June 30th with HR11 Term Date populated
Enrolled into family COBRA coverage July – December (BN70/BN71)

Process:

Run ACA IRS Codes Processing (BN990) to create 1095-C data - see KB Article 1675088
Run ACA COBRA, Retirees IRS Codes (BN991) to update the 1095-C data for the COBRA enrollment

COBRA (BN70/BN71) or Retiree (BN72) expected 1095-C results:

BN990 processing

Offer Code
Jan – June: 1E (from best offer)
July – Dec: 1H (No offer of coverage-individual is not an employee)
Safe Harbor Code
Jan – June: 2C (enrolled)
July – Dec: 2A (Employee with term date and not employed during the month)
Part III
Jan – June: “X”

BN991 processing

Part III
July – Dec: “X” NOTE: Record will be merged with the BN990 results so that “All” months is marked.

1095-C: PART II

All
Jan
Feb
Mar
Apr
May
Jun
Jul
Aug
Sep
Oct
Nov
Dec
Line14

1E
1E
1E
1E
1E
1E
1H
1H
1H
1H
1H
1H
Line15

$
$
$
$
$
$

Line16

2C
2C
2C
2C
2C
2C
2A
2A
2A
2A
2A
2A

1095-C: PART III – Covered Individuals

All
Jan
Feb
Mar
Apr
May
Jun
Jul
Aug
Sep
Oct
Nov
Dec
Line17
X

Line18
X

Line19
X

Note: Line 17 will represent the employee/participant.

Note 2: Line 18, Line 19, Line 20, etc…will represent dependents.

Terminated Employee who has worked in the reporting year but does not elect COBRA coverage (with two dependents).

Example (COBRA):

Employee offered and enrolled in HL benefit coverage from January – June (BN32)
Terminated June 30th with HR11 Term Date populated
No coverage July – December
No enrollment in BN32 and no BN70 or BN71 records

Process:

Run ACA IRS Codes Processing (BN990) to create 1095-C data—see KB Article 1675088
Run ACA COBRA, Retirees IRS Codes (BN991)

COBRA (BN70/BN71) or Retiree (BN72) expected 1095-C results:

BN990 processing

Offer Code

Jan – June: 1E (best offer)

July – Dec: 1H (no offer of coverage-individual is not an employee)

Safe Harbor Code

Jan – June: 2C (enrolled)
July – Dec: 2A (employee not employed during the month)

Part III

Jan – June: “X”

BN991 processing

BN991 does not have anything to evaluate for this terminated employee who did not elect COBRA coverage

1095-C: PART II

All
Jan
Feb
Mar
Apr
May
Jun
Jul
Aug
Sep
Oct
Nov
Dec
Line14

1E
1E
1E
1E
1E
1E
1H
1H
1H
1H
1H
1H
Line15

$
$
$
$
$
$

Line16

2C
2C
2C
2C
2C
2C
2A
2A
2A
2A
2A
2A

1095-C: PART III – Covered Individuals

All
Jan
Feb
Mar
Apr
May
Jun
Jul
Aug
Sep
Oct
Nov
Dec
Line17

X
X
X
X
X
X

Line18

X
X
X
X
X
X

Line19

X
X
X
X
X
X

Note: Line 17 will represent the employee/participant.

Note 2: Line 18, Line 19, Line 20, etc…will represent dependents.

Terminated Employee who has NOT worked in the reporting year due to termination in prior year and has COBRA/Retiree coverage in reporting year (with two dependents).

Example (COBRA):

Employee offered and enrolled in COBRA benefit coverage from January – December (BN70/BN71)
Terminated prior year with HR11 Term Date populated

Process:

Run ACA IRS Codes Processing (BN990) to create 1095-C data—see KB Article 1675088
Run ACA COBRA, Retirees IRS Codes (BN991)

COBRA (BN70/BN71) or Retiree (BN72) expected 1095-C results:

BN990 processing

BN990 does not have anything to evaluate for an employee terminated in a prior year

BN991 processing

Offer Code

Jan – Dec: 1G (Offer of coverage to employee who was not a full-time employee for any month of the calendar year). “All” box marked with an “X”

Cost

Jan – Dec: blank

Safe Harbor Code

Jan – Dec: blank

Part III

“All” months box: “X”

1095-C: PART II

All
Jan
Feb
Mar
Apr
May
Jun
Jul
Aug
Sep
Oct
Nov
Dec
Line14
1G

Line15

Line16

1095-C: PART III – Covered Individuals

All
Jan
Feb
Mar
Apr
May
Jun
Jul
Aug
Sep
Oct
Nov
Dec
Line17
X

Line18
X

Line19
X

Note: Line 17 will represent the employee/participant.

Note 2: Line 18, Line 19, Line 20, etc…will represent dependents.

Terminated Employee who has NOT worked in the reporting year due to termination in prior year and has less than all 12 months of COBRA/Retiree coverage in reporting year (with two dependents).

Example (COBRA):

Employee offered and enrolled in COBRA benefit coverage from January – April (BN70/BN71), then ends COBRA coverage on April 30th
Terminated prior year with HR11 Term Date populated

Process:

Run ACA IRS Codes Processing (BN990) to create 1095-C data—see KB Article 1675088
Run ACA COBRA, Retirees IRS Codes (BN991)

COBRA (BN70/BN71) or Retiree (BN72) expected 1095-C results:

BN990 processing

BN990 does not have anything to evaluate for an employee terminated in a prior year

BN991 processing

Offer Code

Jan – Dec: 1G (Offer of coverage to employee who was not a full-time employee for any month of the calendar year). “All” box marked with an “X”

Cost

Jan – Dec: blank

Safe Harbor Code

Jan – Dec: blank

Part III

Jan – April: “X”

1095-C: PART II

All
Jan
Feb
Mar
Apr
May
Jun
Jul
Aug
Sep
Oct
Nov
Dec
Line14
1G

Line15

Line16

1095-C: PART III – Covered Individuals

All
Jan
Feb
Mar
Apr
May
Jun
Jul
Aug
Sep
Oct
Nov
Dec
Line17

X
X
X
X

Line18

X
X
X
X

Line19

X
X
X
X

Note: Line 17 will represent the employee/participant.

Note 2: Line 18, Line 19, Line 20, etc…will represent dependents.

Full-time Employee who moves to part-time in the reporting year:

Example (COBRA):

Full-time Employee offered and enrolled in HL benefit coverage from January – June (BN32)
Employee loses company health coverage on June 30th when moved to part-time
Enrolled into family COBRA coverage July – December (BN70/BN71) at higher cost

Process:

Run ACA IRS Codes Processing (BN990) to create 1095-C data—see KB Article 1675088
Run ACA COBRA, Retirees IRS Codes (BN991)

COBRA (BN70/BN71) or Retiree (BN72) expected 1095-C results:

BN990 processing

Offer Code

Jan – June: Offer code from best offer plan
July – Dec: 1H

Employee Cost
Jan – June: $ Cost displayed if Offer Code = 1B, 1C, 1D, or 1E
Safe Harbor Code

Jan – June: 2C (Employee enrolled in coverage offered)
July – Dec: blank

Part III

Jan – June: “X”

BN991 processing

Offer Code
July – Dec: Offer code from COBRA/Retiree benefit plan
Employee Cost
July – Dec: $$ Cost displayed if Offer Code = 1B, 1C, 1D, or 1E
Safe Harbor Code
July – Dec: 2C
Part III
July – Dec: “X”

NOTE: Record will be merged with the BN990 results so that “All” months boxes are marked as needed.

1095-C: PART II

All
Jan
Feb
Mar
Apr
May
Jun
Jul
Aug
Sep
Oct
Nov
Dec
Line14

1E
1E
1E
1E
1E
1E
1E
1E
1E
1E
1E
1E
Line15

$
$
$
$
$
$
$$
$$
$$
$$
$$
$$
Line16

2C
2C
2C
2C
2C
2C
2C
2C
2C
2C
2C
2C

1095-C: PART III – Covered Individuals

All
Jan
Feb
Mar
Apr
May
Jun
Jul
Aug
Sep
Oct
Nov
Dec
Line17
X

Line18
X

Line19
X

Note: Line 17 will represent the employee/participant.

Note 2: Line 18, Line 19, Line 20, etc…will represent dependents.

Full-time Employee that moves to part-time in the reporting year and chooses to not elect COBRA coverage (with two dependents).

NOTE: An additional waive plan is required to track active employees who waive an offer of COBRA coverage (terminated employees are covered in Example 2 and do not require a COBRA waive plan). Employees who move from full-time to part-time and waive COBRA coverage, a BN31/BN32 COBRA waive enrollment will need to exist for proper COBRA processing. The COBRA Waive plan is setup with the appropriate ACA parameters. The plan should be set up with a COBRA waive employee group (HR55.2), so only this type of employee is eligible for the COBRA waive.

Example (COBRA):

Full-time Employee offered and enrolled in HL benefit coverage from January – June (BN32)
Employee loses company health coverage on June 30th when moved to part-time
Employee waives family COBRA coverage July – December (BN70/BN71) at higher cost

Process:

Run ACA IRS Codes Processing (BN990) to create 1095-C data—see KB Article 1675088
Run ACA COBRA, Retirees IRS Codes (BN991)

COBRA (BN70/BN71) or Retiree (BN72) expected 1095-C results:

BN990 processing

Offer Code

Jan – June: Offer code from best offer
July - Dec: Offer code from waive COBRA offer (should be the only BN29 offer record for time period)

Employee Cost displayed if Offer Code = 1B, 1C, 1D, or 1E
Safe Harbor Code

Jan – June: 2C (Employee enrolled in coverage offered)
July – Dec: 2B (Employee not a full-time employee—automatically populated by BN990 when the only offer in BN29 is a WV offer)

Part III

Jan – June: “X”

BN991 processing

BN991 does not have anything to evaluate for this full time employee who moved to part time and does not elect COBRA coverage

1095-C: PART II

All
Jan
Feb
Mar
Apr
May
Jun
Jul
Aug
Sep
Oct
Nov
Dec
Line14

1E
1E
1E
1E
1E
1E
1E
1E
1E
1E
1E
1E
Line15

$
$
$
$
$
$
$$
$$
$$
$$
$$
$$
Line16

2C
2C
2C
2C
2C
2C
2B
2B
2B
2B
2B
2B

1095-C: PART III – Covered Individuals

All
Jan
Feb
Mar
Apr
May
Jun
Jul
Aug
Sep
Oct
Nov
Dec
Line17

X
X
X
X
X
X

Line18

X
X
X
X
X
X

Line19

X
X
X
X
X
X

Note: Line 17 will represent the employee/participant.

Note 2: Line 18, Line 19, Line 20, etc…will represent dependents.

sriman-shivakoti

Sorry.

Didn't copy so well but you can look at it on the xtreme site.

manisht

Thank you so much Margie!

barbara-pincheon

We have ran the 990 and are making corrections on bn27.2 and hoping this new patch doesn't affect what we've already completed. Did installing the 991 patch affect any of the other applications that you already ran for the ACA?

sriman-shivakoti

Yes.

WE needed a fix in the 990 for one of our affiliates. The others were ready to go so we opted to produce our 1095 file for the ones that were ready to go with the caveat that they can't rerun or the 1094 won't match.

We will process the one affiliate as soon as they have had a chance to look at the "new" data. Rehires continue to be a challenge in our files if they happen in the 2015 and those that occurred in 2016 and now have a HL benefit record.

We are using BN27.2 to fix them as well.

[Updated on 1/20/2016 10:17 AM]

deb-lopez

We are going to use the BN597 to upload outside resources. In this case, we are adding our cobra/retirees this way. The documentation does not say anywhere that we can find what the name of the file is that the BN597 will be looking for in the WORK folder on the Lawson server. Has anyone used this and know what we need to name our upload spreadsheet in the WORK folder?

Robert Canham

I haven't tried the BN597, but usually if you create a job and run it, it will give you the work file path and name in the print file and tell you no file found. (Test first of course)

[Updated on 1/22/2016 8:50 AM]

mp33580

If we use BN597 to upload offers for terminated employees that enrolled in COBRA or Employees that lost coverage during the year but remained active and enrolled in COBRA, and create a second BN15 COBRA Waive plan for employees that lost coverage during the year but didn't elect coverage, will we accomplish the same thing as going through all of the setup work required to get enrollments put on BN70/BN71 which we don't use?

unknown

@mp33580. Were you able to get an answer on this anywhere? I too am curious about this. As we currently do not keep out Cobra enrollments in Lawson. Can we just use the 597 to upload the information? Do we need to worry about any of the Cobra set up?

paco-gayosso

Thank you everyone for responding. Someone replied and said they used PR39.2 which would update the current year's deductions. These were for prior year deductions, but since they did not impact BN32.1, it was not bothering anyone. I tested it and reran the PR140 and received the results I was expecting.

mp33580

Tina McCool - I did not get an answer on this from anyone -so we created an offer file and uploaded it with BN529. We didn't set up medical plans for COBRA coverage but did create a COBRA waive plan. The BN297 - 1095.csv didn't have the best offer costs loaded for the employees that became ineligible during the year and elected COBRA. So we are going through the 1095.csv to get the costs in and verify the covered dependents. We have under 100 employees that elected COBRA so this isn't too cumbersome but it would be really nice to get exact procedures for loading COBRA participants that aren't stored on BN70/71. It seems like I must have missed something but I thought I read everything that was out there.

manisht

mp33580 - I am struggling with setting up the COBRA Waive plan and connecting the COBRA premiums for each coverage type. Would you be willing to send me the setup details of your COBRA waive plan ? I feel like I have to be missing something simple...

As far as the processing overall goes, I am under the impression from the documentation that you have to setup all of you COBRA and Retiree's in BN71/Bn72/Bn72 so that the BN991 will be able to apply the code logic appropriately for these employees. ultimately this will then then be picked up in the BN297. I agree though that another option to load them in would be helpful for those of us who do not handle COBRA in Lawson today.

mp33580

I literally just created a waive plan and made it available only to COBRA participants as was documented in the "What is the ACA COBRA IRS Codes Processing logic (BN991)" document on page 7. I don't have any premiums on the waive plan. I am in the process of setting up a BN15 Medical plan for COBRA only with the option amounts and then I'll attempt to enroll the employee on BN71 and run BN991 and then BN297. It seems a bit much to have to go through this extra work.

Mary

unknown

Thank you for the information. I wish there was more information available as well. I am struggling here. I had assumed that we would be able to upload the information without having to set each one up.

[Updated on 1/27/2016 4:00 PM]

0712131256598360.doc

mp33580

Me too. I just enrolled someone in the COBRA medical plan and ran the BN991 and it worked as advertised so we are just going to create BN70/BN71 records for everyone. From what I can tell we only have to put Waive plans on the employees that went from Full-Time to part-time and waived COBRA, not people that termed and waived COBRA. But I could be wrong on that too.

mp33580

Dumb question - if a 1E plan for employees is offered as COBRA, is it still 1E or is it 1F?

plancor

We have ours set to 1G (but we are self insured).

unknown

And in the Safe Harbor code for COBRA terms.
Are you putting 2A (Employee not employed) or a different safe harbor code

mp33580

What are you doing for employees that went from full-time to part-time and elected COBRA? If they elect COBRA for a 1E plan is it still a 1E plan - seems like it shouldn't be because it's not MEV anymore. I can't use 1G for them because it says that they weren't a full-time employee in any month of the year.

Nick we are using 2A for the employees that terminate and 2C for the ones that went from full-time to part-time and elected.

unknown

I was going to use 1G, but only during those months of COBRA

flyer_new_global_messages.pdf

unknown

We are using 2A for termed employees whether cobra was elected or not. I believe Lawson will default to 2C for employees that became ineligible and elected COBRA.

[Updated on 1/29/2016 7:39 AM]

unknown

When enrolling an ACTIVE employee in the COBRA waive plan (employee moved to a benefit-ineligible status but has not termed), does he/she need to be in the waive plan just for the calendar year in which he/she initially waived COBRA or do we need to show the waive plan for the full 18 months he/she could have had COBRA?

unknown

Has anyone here successfully uploaded ACA Resources via the layout template provided by Infor Doc: 46020, referenced in KB article?

I have the template created and we have tried several times to upload to import our cobra participants, via BN597, as a resource. However, we continue to receive a multitude of errors. Looking further at the template, it appears it may only be for versions 10x. We are currently on 9x still... I have looked for other templates, to no available. Any ideas?

201008_monthly_proactive.pdf

unknown

Are there instructions for adding information to the BN70/BN71 that I may have missed?

unknown

What is the Occurrence Type on the BN70?

dEPM-432 - Infor dEPM Dashboards and Mobile - What's New.mp4

unknown

The occurrence type is the reason for why COBRA was offered (i.e. termination, reduced hours, death of employee).

unknown

That's what I thought. Do you know if Lawson has them listed somewhere to do we determine our own?

0712050808501819.doc

unknown

I am not getting the correct employee COBRA costs after running the BN991. I have the options set up in BN15 (BN19.1), but it shows the regular employee rate. What am I missing?

unknown

The COBRA Occurrence Type is defined on BN00.3.

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