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Definition – Increasing ACA content knowledge of employer-based team members who are responsible for any part of the ACA process and/or reporting.

Rationale – Given 1) The complexity of the ACA and 2) The materiality of potential IRS penalties employers cannot afford to not have at least one ACA knowledgeable employee.

1. Counting Hours to Determine ACA Eligible Employees – Employers with part-time and variable hour employee populations must make sure their respective Standard Measurement Periods and Initial Measurement Periods (for on-going new hires) are handled appropriately. Moreover, newly eligible employees must be offered coverage in a timely manner as well. If either of these elements are handled incorrectly, the potential for costly penalties is high.

2. ACA Data – ACA data applies to active and inactive employees that are part of any related control group of companies. More specifically, indicative, benefits, health insurance and time & attendance data comprises the ACA data universe.

Action Plan

  1. Identify key users and responsible parties in either Finance, HR and IT.
  2. Assess ACA skill levels.
  3. Provide training.
  4. Provide refresher courses.

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)