Navigating IRS Deadlines for ACA Forms: What ALEs Must Know
If your organization is classified as an Applicable Large Employer (ALE) under the Affordable Care Act (ACA), staying on top of IRS deadlines for ACA forms is crucial to avoid costly penalties and ensure compliance. The ACA’s reporting requirements can be complex and demanding, especially when juggling employee data across multiple systems. This comprehensive guide will walk you through the essentials ALEs need to know about ACA form deadlines, the data you need to track, and how to streamline compliance efficiently.
What is an Applicable Large Employer (ALE)?
An Applicable Large Employer (ALE) is generally any employer with 50 or more full-time employees or full-time equivalents (FTEs). ALEs are subject to the ACA’s employer shared responsibility provisions, meaning they must offer affordable, minimum value health coverage to full-time employees and their dependents or potentially face IRS penalties if those employees receive premium tax credits on the Health Insurance Marketplace.
The ACA defines a full-time employee as someone working on average at least 30 hours per week or 130 hours per month. Calculating the total workforce size includes counting full-time employees plus FTEs derived from part-time hours.
Why Tracking Employee Hours Is Vital
Tracking actual hours worked by all employees — including variable-hour and part-time workers — is essential for determining ACA eligibility and compliance:
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It helps identify which employees meet the full-time threshold.
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It documents employee hours in case of IRS audits or disputes.
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It protects employers from penalties related to offering (or failing to offer) coverage.
If hours aren’t accurately tracked, the employer risks paying penalties for failing to offer coverage to employees who qualify as full-time under ACA rules.
Key IRS ACA Form Deadlines ALEs Must Know
1. Form 1095-C: Furnishing to Employees
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Due Date: January 31st (for the prior tax year)
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This form provides employees with detailed information about the health coverage offered by their employer.
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The IRS has occasionally extended this deadline by 30 days, but it’s best to plan for the January 31st due date to ensure timely delivery.
2. Form 1094-C: Filing with the IRS
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Due Date: March 31st (for the prior tax year)
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The 1094-C form is the transmittal that summarizes the data reported on all the 1095-Cs.
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Unlike Form 1095-C, there have been no extensions granted for the 1094-C filing deadline since 2015.
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Employers with 250 or more employees must file these forms electronically.
Failing to meet these deadlines can result in significant penalties.
Penalties for Missing ACA Reporting Deadlines
The IRS imposes escalating penalties depending on how late the forms are filed or furnished:
| Timing of Late Filing/Furnishing | Penalty per Form | Maximum Penalty |
|---|---|---|
| Less than 30 days late | $50 | $194,500 |
| 31 days late until August 1 | $110 | $556,500 |
| After August 1 | $270 | $1,113,000 |
Note: Penalties double to $540 per form if the employer neither files nor furnishes the required statements.
The Challenge: Managing Complex ACA Data and Reporting
Compiling accurate ACA data requires coordination across multiple departments — HR, payroll, benefits, and finance. You must track:
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Employee hours worked, including variable-hour and part-time staff.
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Full-time equivalent employee calculations.
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Employee insurance offers and coverage status.
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Waivers and changes in employee status.
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Accurate employee data such as hire and termination dates.
Data is often scattered across different systems, making the ACA reporting process complicated and prone to errors without a centralized solution.
How ACA-Track Simplifies ACA Compliance
ACA-Track offers a proven ACA compliance solution designed to streamline tracking, monitoring, and reporting — all while helping you meet IRS deadlines with confidence.
Why Choose ACA-Track?
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Comprehensive Data Collection: Gathers actual hours worked for all employee types from multiple systems (payroll, time clocks, manual entries).
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Automated Monitoring: Alerts you when employees approach eligibility thresholds, so you never miss an offer requirement.
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Accurate Reporting: Generates IRS-ready 1094-C and 1095-C forms and supports electronic filing in the proper XML format.
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Error Correction: Quickly identify and fix ACA reporting errors before submission.
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User-Friendly Interface: Customize your dashboard and filters to focus on the data you need, complete with snapshot summaries preserving data history.
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Dedicated Support: A client success advisor guides you through setup and ongoing compliance.
Security & Integration
ACA-Track securely stores employee ACA data, complying with industry standards like SOC 2 type 2, SSAE 16, and encrypted data transfers. It seamlessly integrates with any payroll or HRIS system for a smooth data flow.
Steps to Ensure Timely ACA Filing
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Determine Your ALE Status annually based on the previous calendar year’s workforce.
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Collect and Monitor Employee Hours Worked accurately throughout the year.
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Use an ACA Tracking Solution like ACA-Track to centralize and automate compliance tasks.
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Prepare and Distribute Form 1095-C to employees by January 31.
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Submit Form 1094-C and 1095-Cs to the IRS by March 31 electronically if you have 250+ employees.
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Respond Quickly to IRS Letters such as the 226-J penalty letter, if applicable.
Final Thoughts
Navigating ACA deadlines can be overwhelming, but compliance is non-negotiable for ALEs. Penalties for late or inaccurate filing can cost thousands — or more — so proactive management is essential.
Using a dedicated ACA compliance service like ACA-Track not only reduces risk but also simplifies the entire ACA process. From tracking employee hours to generating IRS-ready forms, ACA-Track offers the tools and expertise to help your organization stay compliant and confident.
Ready to take the stress out of ACA compliance? Explore ACA-Track and their tailored solutions today to ensure your company never misses a deadline again.
Visit ACA-Track to learn more.
If you want, I can help draft additional posts about ACA penalties, employee tracking best practices, or deep dives on IRS filing processes! Just let me know.
