ACA reporting may happen during the first few months of the year, but reporting accuracy depends on what employers track throughout the year.
Full-time status determinations, coverage offers, employee contributions and enrollment changes all feed into Forms 1094-C and 1095-C. If that information is incomplete or inconsistent, waiting until reporting season leaves little time to investigate discrepancies. Employers may be able to correct a form, but they cannot retroactively make a coverage offer or change what an employee was charged months earlier.
Reviewing ACA reporting requirements before January gives HR and benefits teams time to find gaps while payroll, enrollment and eligibility records are still readily available.
Why ACA reporting should be reviewed before January
Applicable Large Employers (ALEs), generally those with an average of at least 50 full-time and full-time-equivalent employees during the previous calendar year, must report information about the coverage offered to full-time employees. Employers that sponsor self-insured health plans also have reporting responsibilities under Section 6055, regardless of employer size. Non-ALE self-insured employers generally use Forms 1094-B and 1095-B, while self-insured ALEs use Forms 1094-C and 1095-C. The IRS explains these reporting distinctions in its current Form 1094-C and 1095-C instructions.
These forms reflect activity across the entire calendar year. A change in an employee’s hours, eligibility, coverage offer or contribution amount can affect how one or more months are reported.
Errors discovered during filing season may require HR teams to review records across multiple systems while working against the 1095-C filing deadline. More importantly, some reporting discrepancies can reveal an underlying compliance issue. An incorrect offer-of-coverage code can be fixed. A required offer that was never made cannot.
What should employers review before ACA reporting season?
The following ACA compliance checklist can help employers identify missing or conflicting information before year-end.
Confirm ALE status
Review workforce counts for each month, including full-time and full-time-equivalent employees. Employers under common ownership may need to combine employee counts when determining ALE status, even though each member of the aggregated group has separate reporting responsibilities.
Changes caused by acquisitions, mergers, new entities or workforce growth deserve particular attention.
Review full-time employee classifications
Compare employee hours and full-time classifications across payroll, human resources and benefits administration records. Look closely at variable-hour, part-time and seasonal employees whose status may change under the employer’s measurement method.
Employers using the look-back measurement method should confirm that measurement, administrative and stability periods were applied consistently. The IRS generally defines a full-time employee as someone averaging at least 30 hours of service per week or 130 hours during a month.
Verify coverage offers and waivers
Make sure each full-time employee’s record shows when coverage was offered, when it became effective and whether the employee enrolled or waived coverage. New hires, employees returning from leave and workers moving between part-time and full-time status often require additional review.
Waivers should be retained as documentation, but an employee’s decision to decline coverage does not remove the employer’s responsibility to make a qualifying offer.
Recheck affordability
Confirm which affordability safe harbor the employer is using and test employee contributions against the adjusted percentage for the applicable plan year. The three available safe harbors are based on Form W-2 wages, rate of pay or the federal poverty line.
If employee contributions or payroll schedules changed during the year, verify that coverage remained affordable after the change. The applicable affordability percentage is adjusted periodically, so employers should use the figure for the year being tested.
Review dependent information
Self-insured employers must report enrollment information for covered employees and family members. Check names, Social Security numbers or other taxpayer identification numbers, birth dates and months of coverage for missing or conflicting information.
Employers should also document their efforts to request missing identification numbers when required.
Reconcile data between systems
Compare payroll, HR, benefits administration and carrier data before forms are created. Employee names, hire and termination dates, coverage dates, contribution amounts and employment status should align across each source.
A clean file from one system does not guarantee accurate reporting if another system contains different information.
Account for plan and workforce changes
Review any midyear changes to plan design, waiting periods, employee contributions or eligibility rules. Employers should also account for mergers, acquisitions, reductions in force and changes within an aggregated employer group.
Each change should be reflected in the monthly data used for ACA reporting.
Common ACA reporting problems to watch for
Frequent issues include employee names or Social Security numbers that do not match IRS records, inconsistent full-time classifications between payroll and benefits systems, missing coverage months and incorrect offer or safe-harbor codes.
Employers should also monitor IRS filing responses. A submission marked “Accepted with Errors” still requires review, and corrected forms may be needed. The current IRS instructions explain how to correct inaccurate employee information, coverage codes, contribution amounts and covered-individual data.
Electronic filing is generally required when an employer files 10 or more information returns in aggregate during the calendar year. Penalties may apply for late, incomplete or incorrect filings and statements. Separate Employer Shared Responsibility Payment exposure may apply when an ALE fails to offer minimum essential coverage that is affordable and provides minimum value to at least 95% of its full-time employees and their dependents, and at least one full-time employee receives a premium tax credit. Current IRS guidance explains the 95% standard and related requirements.
Preparing for 2026 ACA reporting
Coverage provided during 2026 will be reported in early 2027. Employers should confirm the exact filing and furnishing deadlines once the IRS publishes its final 2026 form instructions.
Current rules provide an automatic 30-day extension of the standard deadline for furnishing recipient statements. Employers may also satisfy the federal furnishing requirement by posting a clear and accessible website notice and providing a Form 1095-C upon request within the required timeframe. Employers considering this option should review the final 2026 IRS instructions and any applicable state requirements before changing their process.
How ebm’s ACA File service helps
ACA reporting requires information from several sources, and HR teams are often responsible for identifying discrepancies before forms can be filed.
ACA File helps employers and their broker partners prepare and submit ACA-required reporting. Support includes reviewing reporting data, preparing Forms 1094-C and 1095-C, electronic filing and addressing corrections when necessary. This gives employers a more structured process for moving from year-round workforce and coverage records to completed filings.
It also reduces the administrative burden placed on HR during an already busy time of year while helping employers address data issues before they create reporting delays or unnecessary penalty exposure.
Get ahead of ACA reporting season
January should not be the first time your organization reviews its ACA data. Starting before year-end provides more time to reconcile records, investigate missing information and prepare for filing.
Contact ebm or speak with your broker to begin preparing for the upcoming ACA reporting season.
