ACA Compliance in 2025: What’s Changed and What Hasn’t
The Affordable Care Act (ACA) has been a cornerstone of American healthcare law for over a decade, continually evolving in response to legislative, administrative, and technological changes. As we move through 2025, it’s essential for employers—especially Applicable Large Employers (ALEs)—to understand what aspects of ACA compliance remain steady, which have changed, and how to adapt effectively.
In this blog post, we’ll explore the current landscape of ACA compliance, highlight ongoing challenges, and show how trusted solutions like ACA-Track can simplify the complexities of ACA tracking and reporting.
What Hasn’t Changed: The Core ACA Compliance Requirements
Despite various policy shifts over the years, certain ACA compliance fundamentals remain steadfast in 2025:
1. Applicable Large Employer (ALE) Status
The threshold defining ALEs is unchanged: Employers with 50 or more full-time or full-time equivalent (FTE) employees are subject to ACA employer shared responsibility provisions. This includes tracking actual hours worked by part-time and variable-hour employees to determine full-time status accurately.
2. Full-Time Employee Definition
Full-time remains defined as an employee working an average of 30 hours per week or 130 hours per month. Tracking these hours continues to be crucial, especially for part-time or variable-hour workers whose status can fluctuate.
3. Employer Shared Responsibility
ALEs must offer affordable, minimum value coverage to full-time employees and their dependents—or face penalties if employees receive premium tax credits through the Health Insurance Marketplace.
4. Reporting Requirements
Filing Forms 1095-C (to employees) and 1094-C (to the IRS) remains mandatory. Deadlines remain consistent, with employee forms due by January 31 (with some extensions) and IRS transmittals due March 31 annually.
What Has Changed: New Developments and Ongoing Challenges in 2025
1. Increased IRS Enforcement and Penalties
The IRS has ramped up enforcement efforts post-pandemic, scrutinizing data quality and timeliness. Penalties for late or incorrect filings remain significant:
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Up to $270 per return for filings submitted after August 1 (doubled to $540 if not furnished to employees)
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Shared responsibility penalties of $2,000 per full-time employee for not offering coverage, or $3,000 per subsidized employee for unaffordable coverage
Employers receiving IRS 226-J penalty letters must respond swiftly, with documentation proving compliance or correcting errors.
2. More Complex Variable Hour Tracking
Employers face ongoing challenges managing variable hour and seasonal employees’ eligibility for coverage. The pandemic accelerated the need for flexible measurement periods and real-time monitoring, which are now expected best practices.
3. Technological Enhancements
Cloud-based ACA compliance software like ACA-Track has advanced with customizable dashboards, automated line code audits, and seamless payroll system integrations. These tools now offer:
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Real-time Variable Hour Tracking
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Monthly 1095-C line code audits
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Automatic electronic IRS filings
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Easy correction of ACA reporting errors
Such improvements help employers reduce manual errors and avoid costly penalties.
4. Data Privacy and Security
With increasing data breaches nationwide, ACA-Track and similar services emphasize strong security measures:
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Encryption of all personal data
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Secure HTTPS data transfers
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Compliance with SSAE 16 and SOC 2 Type 2 certifications
This focus ensures sensitive employee information stays protected while maintaining compliance.
Why Tracking Variable and Part-Time Employees Remains Critical
One constant challenge is monitoring the hours worked by part-time or variable-hour employees. Failing to track these hours can lead to inaccurate ACA reporting, penalties, and employee dissatisfaction.
Remember:
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If you do not track actual hours, the default assumption can favor the employee, potentially triggering penalties.
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Tracking supports accurate offers of coverage and substantiates compliance during IRS audits.
How ACA-Track Simplifies ACA Compliance in 2025
Managing ACA compliance internally can be a tangled web of spreadsheets, multiple departmental inputs, and evolving IRS requirements. This is where ACA-Track steps in with a comprehensive solution.
Key Features of ACA-Track Include:
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Collect: Gathers actual hours worked from diverse sources (timekeeping systems, payroll, manual entries) for all employee types, including part-time and substitutes.
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Monitor: Automatically tracks employee eligibility, offers early alerts for threshold breaches, and monitors waivers and leaves.
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Report: Generates accurate 1094-C and 1095-C forms ready for IRS electronic filing, simplifying the entire reporting process.
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User-Friendly Interface: Customizable dashboards, snapshot summaries preserving historical data, and intuitive filtering help users quickly identify compliance issues.
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Flexible Configuration: Adapt measurement, administrative, and stability periods; configure affordability percentages, waiver codes, and new hire measurements.
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Security and Compliance: Hosted in SAS 70 certified and SOC 2 Type 2 compliant data centers with encrypted data handling.
With a dedicated Client Success Advisor, ACA-Track supports your compliance journey every step of the way.
Conclusion: Staying Ahead in ACA Compliance
ACA compliance in 2025 still demands rigorous tracking, accurate reporting, and careful attention to IRS regulations. While some foundational rules remain unchanged, the increased enforcement and data management complexities make it critical for employers to adopt reliable technology and expert support.
If you want to confidently navigate ACA compliance this year and beyond, consider exploring ACA-Track, a trusted partner offering proven ACA compliance services tailored to your organization’s unique needs.
If you have questions about ACA compliance or want to learn how ACA-Track can fit your business needs, visit their website or get in touch with a dedicated advisor for a personalized consultation.
