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May 27, 2025 By Mark

How to Tell If Your Business Qualifies as an Applicable Large Employer

How to Tell If Your Business Qualifies as an Applicable Large Employer

How to Tell If Your Business Qualifies as an Applicable Large Employer

Navigating the Affordable Care Act (ACA) requirements can be complex for many businesses. A critical starting point is understanding whether your company qualifies as an Applicable Large Employer (ALE), because this designation carries important health coverage obligations under the ACA. This blog post will walk you through how to determine if your business is an ALE, explain why it matters, and highlight how a trusted ACA compliance partner like ACA-Track can help simplify this process.


What is an Applicable Large Employer (ALE)?

An Applicable Large Employer is a company that employs 50 or more full-time employees, including full-time equivalent employees (FTEs). ALE status determines if your company is subject to ACA’s employer shared responsibility provisions, which require offering affordable, minimum value health insurance coverage to full-time employees (and their dependents), or else potentially facing penalties.


How to Calculate If Your Business Is an ALE

Step 1: Count Your Full-Time Employees

A full-time employee, according to the ACA, is someone who works:

  • On average, 30 hours or more per week, or

  • At least 130 hours per month

If your business has 50 or more such employees, you likely are an ALE.

Step 2: Calculate Full-Time Equivalent Employees (FTEs)

FTEs are calculated by combining the hours worked by part-time and variable hour employees (up to 120 hours per employee per month), then dividing the total by 120.

For example, if you have:

  • 40 full-time employees, plus

  • 20 employees who each worked 60 hours in a month (total 1,200 hours),

You would calculate FTEs as follows:

  • 1,200 hours ÷ 120 = 10 FTEs

  • Total full-time employee count = 40 + 10 = 50 employees

In this example, you would be an ALE.


Why ALE Status Matters

If your business qualifies as an ALE, you are legally obligated to:

  • Offer health insurance that meets ACA standards to full-time employees and their dependents,

  • Report your coverage offers and enrollments annually to the IRS, and

  • Avoid or face penalties if you fail to comply.

Non-compliance can result in significant fines, including:

  • Penalties up to $2,000 per full-time employee (excluding the first 30), and

  • Additional fees for filing ACA reports late or with errors.


Why Tracking Actual Hours Worked is Crucial

For part-time and variable hour employees, tracking actual hours worked is essential. This data determines whether those employees reach full-time status during ACA measurement periods and are thus eligible for coverage.

Failing to track hours can expose your business to:

  • Penalties if an employee obtains a Marketplace subsidy because you didn’t offer coverage, and

  • Difficulty defending your compliance status in an IRS audit.


Which Departments Manage ACA Compliance?

ACA compliance data spans multiple departments:

  • Payroll: Tracks hours worked and compensation data,

  • Human Resources: Manages employee status, hire and termination dates, and coverage eligibility,

  • Benefits: Oversees health insurance offers and waivers, and

  • Finance: Manages tax filings and budget impacts.

Collaborative efforts are vital for successful ACA compliance management. Many companies assign responsibility to the CFO, HR Director, or Benefits Manager.


Simplifying ACA Compliance with ACA-Track

Given the complexities involved, many companies turn to specialized ACA compliance services for assistance. One standout solution is ACA-Track, which offers:

  • Comprehensive ACA compliance tracking: Captures hours worked for all employee types—full-time, part-time, variable hour, and substitutes—across multiple data sources (payroll, timekeeping systems, manual entries).

  • Real-time eligibility monitoring: Tracks employee eligibility thresholds and alerts you in advance of any changes, including waivers and leaves.

  • Automated federal and state reporting: ACA-Track produces IRS Forms 1094-C and 1095-C and supports electronic XML filing, helping you avoid penalties for late or incorrect filings.

  • Monthly line code audits: Ensures accuracy and compliance of all reporting data.

  • User-friendly customizable dashboards: Helps you sort, filter, and analyze ACA data easily with color-coded warnings for errors or anomalies.

  • Secure cloud-based platform: Data encryption, HIPAA-safe practices, and compliance with SSAE 16 and SOC 2 Type 2 standards protect your sensitive employee data.

ACA-Track even assigns a dedicated Client Success Advisor to guide you every step of the way, making ACA compliance easier and less stressful.


Key Takeaways

  • If your business employs 50 or more full-time employees (including FTEs), you are an ALE and subject to ACA employer mandates.

  • Accurately tracking all employee hours worked—including part-time and variable hour employees—is crucial to determining coverage obligations.

  • Collaboration across payroll, HR, benefits, and finance departments is essential for accurate ACA reporting and compliance.

  • Partnering with a trusted ACA compliance solution like ACA-Track can help you automate data collection, eligibility monitoring, reporting, and reduce the risk of costly penalties.


Final Thought

ACA compliance isn’t just a regulatory hurdle—it’s a significant responsibility with potential financial consequences. Early identification of your ALE status and implementing robust tracking and reporting systems will safeguard your business and employees.

Explore how ACA-Track can help your company streamline ACA compliance through proven technology and dedicated support. Take control of your ACA obligations today!

Filed Under: ACA Compliance

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Information provided by PSST, LLC concerning the Affordable Care Act is not legal advice and should not be treated as such. If you have questions about how the Affordable Care Act will affect you as an employer, please consult legal counsel.

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