ACA Compliance and Reporting

The first question: are you an applicable large employer?

The Affordable Care Act’s employer obligations turn on whether you average 50 or more full-time and full-time-equivalent employees. Part-time hours count toward that calculation, which is why employers with a large hourly or seasonal workforce sometimes cross the threshold without realizing it.

Getting this wrong in either direction is costly. Employers who are subject and do not know it face penalties. Employers who assume they are subject and are not sometimes buy coverage structures they never needed.

Affordability and minimum value

If you are an applicable large employer, offering coverage is only half the requirement. The coverage has to meet a minimum value standard, and the employee’s share of the lowest-cost self-only option has to fall within an affordability percentage that the IRS adjusts each year.

That percentage moves. A contribution structure that was affordable last plan year is not automatically affordable this one, and the safe harbor you use to prove it changes the math. We test this against your actual contribution schedule rather than assuming last year’s answer still holds.

Reporting

• Form 1095-C furnished to each full-time employee
• Form 1094-C transmitted to the IRS
• Correct offer-of-coverage and safe harbor codes on each line
• Coordination with your payroll and enrollment data so the codes match reality

Most reporting penalties we see are not from employers who refused to offer coverage. They are from employers who offered good coverage and coded the forms wrong.

Ongoing, not annual

Compliance is easier when it is checked at renewal rather than reconstructed in January. We build the affordability review into your renewal conversation, so contribution changes get tested before you announce them to staff.