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Definition – Getting indicative, benefits, health insurance and time & attendance data ready for staging into the Counting Hours and/or ACA IRS Reporting environment.

Rationale – Much like the real estate adage “location, location, location” in the ACA world the adage is “data, data, data.” To that end, the data must be assembled and reviewed prior to “prime time” to ensure the data will achieve desired goals.

1. Indicative Data – Indicative data pertains to ACA eligible census data which also includes mid-year new hires as well as terminations.

2. Benefits Election Data – Health insurance-related eligibility and enrollment information (e.g. eligibility date, lowest cost monthly premium for single only coverage, enrollment start/stop date, waiver dates) for ACA eligible employees and family members (for self-insured plans).

Action Plan

  1. Review indicative data
  2. Review time & attendance data
  3. Review benefits data
  4. Review health insurance data (if not included in the benefits data)
  5. Identify data gaps
  6. Fill data voids


Since we are no longer in a “best efforts” year, employers should embrace best practices or simply accept the dire likelihood of material penalties. In order to mitigate future risks employers should thoroughly review and improve their supporting processes and technologies. Employers have the opportunity to fortify their environments and avoid penalties. As they say, “there’s no time like the present – do it now!”


About The Author: Howard Gerver, of ACA Managed Services, is an authority on 1095 compliance. He and his team of ACA experts are the go-to specialists for companies who wish to avoid trouble with the IRS. They offer a range of ACA services, including ACA audits (also known as 1095 audits)