A Monthly Survival Checklist for ALEs

The Affordable Care Act (ACA) imposes specific requirements on applicable large employers regarding healthcare coverage and reporting to the Internal Revenue Service (IRS). To ensure a seamless filing process and compliance with ACA regulations, ALEs must follow a monthly checklist of tasks. In addition to this checklist, ALEs must ensure specific tasks are completed promptly during the annual ACA filing season.

Below are important actions ALEs need to take throughout the year.

SyncStream’s Monthly ACA Checklist

January - December:

• Monitor current employees' full-time status and service hours using monthly or look-back measurements.
• Offer affordable Minimal Essential Coverage (MEC) and provide minimum value to newly hired full-time employees, newly calculated full-time-equivalent employees (FTEs), and their dependents within the first three full calendar months of employment.
• Upload necessary data, including:
•  Payroll (if applicable)
• Census with hiring dates /termination dates /edits
• Offer of Coverage Data
• Health Benefits Plan Summary Data
• Confirm all calculations for employee status, and affordability are accurate and use the proper year’s numbers provided by the IRS annually.
• Ensure accuracy in applying all ACA indicator codes per employee per month on the 1095-C.

Mid-Year Check

• Attest that all payroll, census, insurance plan data, and offers of coverage data are accurate and have been reviewed.
• Double-check calculations.
• Spot-check indicator codes for accuracy and consistency.
• Confirm all Plan data has been updated for coverage through the end of the year.
• Ensure that the Measurement, Administrative, and Stability Periods are aligned appropriately with the dates of your plan period, open enrollment, and waiting periods.
• This is also an excellent time to confirm SSN with Social Security Number Verification Service.

January (Reporting Season Checklist):

• Review the health coverage offered and provided to full-time employees and their dependents for the previous calendar year.
• Prepare proper 1095-C forms for all full-time, calculated full-time, and self-funded plan enrollees.
• Confirm the accuracy of all calculations conducted leading up to reporting season.
• Attest to the accuracy and consistency of applied indicator codes.
• Review the health coverage offered and provided to full-time employees and their dependents, explicitly checking to ensure the coverage meets the employer-mandated Affordable Minimum Essential Coverage requirements and provides Minimum Value.
• Verify the accuracy and completeness of the payroll and benefits data for the previous year.
• Verify the accuracy and completeness of the calculations and confirm that those calculations used the required mandated numbers for that reporting year.
• Confirm all Full-Time, Calculated Full-Time, and anyone who elected to a self-funded plan has a proper 1095-C form prepared.



February (Reporting Season Checklist):

• Review, audit, and complete penalty assessment for each form prepared for filing with the IRS.
• Prepare to furnish Form 1095-C to eligible employees (full-time, full-time equivalent, or elected into a self-funded plan) by March 2nd each year. 
• If filing on paper, employers filing less than ten 1095-C forms may file on paper: File Form 1094-C and copies of Form 1095-C with the IRS by February 28th.

March (Reporting Season Checklist):

• Complete all edits found by the employer, employee, or third-party preparer, ensuring revisions are completed on the forms and in the source data so those errors don't appear next year. 
• File Form 1094-C and copies of Form 1095-Cs ELECTRONICALLY with the IRS by March 31st of each year.
• Respond to any inquiries or notices from the IRS or employees regarding Forms 1094-C and 1095-C as soon as possible. 
• Confirm that the IRS provided a Receipt ID with an Accepted or Accepted with Errors status. All other responses required additional work before closing out the reporting year. 
• After confirmation, collect all reporting data and copies of all documents and correspondence with the IRS, AIRs, and Third-Party ACA Preparer and file for your records. 
• Close out the reporting year. 

Special Note:

Monitor current employees' full-time status and service hours using the monthly or look-back measurement method.  The IRS automatically provides this 90-day limited non-assessment period for employers to take action and where penalties will not be assessed. Data suggested for monthly upload include payroll (Monthly Measures must provide payroll from the 1st-31st for calculations to be accurate), census with the month's Hire/Terms/Edits, Offer of Coverage Data with the Month's Offers/Elections/Waives/Dis-enrollments. For those preparing forms by hand, a monthly assessment of 1095 codes and all ACA calculations, including but not limited to the numbers needed for 1094-C Part III (Lines 23-25, columns a-c), is recommended as the actions of the month are fresh opposed to waiting until the end of the year.

Key Take-Aways:

• By following this monthly checklist, adhering to the regulations, and utilizing robust compliance software like SyncStream Solutions, ALEs can ensure compliance with the ACA regulations and streamline their filing process.

• Monitoring employee status, offering affordable coverage, and maintaining accurate data uploads are crucial for a seamless filing experience.

• It is essential to review and confirm the accuracy of all calculations and indicator codes throughout the year and, if available, have a full audit conducted for all forms before filing with the IRS so that, as an employer, you are aware of your penalty risks before you submit your ACA reporting.

• ACA Audits by SyncStream Solutions allow ALEs to preview the potential ACA penalty risk, make the proper corrections, and ensure compliance with the Affordable Care Act.

About SyncStream

SyncStream maintains a tenured, knowledgeable staff who continually monitors changes to the employer mandate regulations and updates solutions as laws evolve. SyncStream removes the burden of ACA compliance and provides penalty risk assessments and suggested corrections to reduce your company’s risk of high IRS penalties. Subject matter experts utilize SyncStream’s user-friendly compliance software to track employee hours, auto-populate forms, audit forms, and e-file for thousands of ALEs. SyncStream’s Full Service Total ACA solution can simplify your ACA compliance needs.