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ACA Compliance Resources

ACA Compliance Resources

Monthly Tracking for 1095-C Compliance


At the minimum, in order to populate IRS Form 1095-C for all of your ACA-defined full-time employees, you must keep:

  • Monthly records of every employee’s hours of service
  • Monthly records of the coverage offered to every employee
  • Monthly records of the attributes of the coverage offered
  • Monthly records of the employee census to track new hire and termination dates

The tracking listed above is what’s needed for an employer with a stable workforce who has always offered quality health care coverage at minimal cost to employees.

If, however, your company offers limited or no coverage, and your workforce can be described by any of the following (hourly workers with varying schedules, lower-wage workers, high turnover), then you also need to do deeper tracking in order to manage the risk of penalties:

  • Monthly monitoring of employee eligibility for coverage
  • Forecasting for which variable-hour employees are trending toward full-time status
  • Monthly tracking, by employee, of offers of coverage
  • Testing for the affordability of coverage offered, including safe harbor calculations

What an employer must do and when with ACA reporting

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Last Review:   8/12/2022 – Revision: 2.0

Applies To:   ACA Reporting Requirements, ACA Compliance solution

Categories:  Monthly Actions

Keywords:  Outline, Monthly records

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