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May 27, 2025 By Mark

Why Tracking Employee Hours Is Critical Under ACA

Why Tracking Employee Hours Is Critical Under ACA

Why Tracking Employee Hours Is Critical Under ACA

The Affordable Care Act (ACA) has profoundly impacted how employers manage and report employee health coverage. For Applicable Large Employers (ALEs) — those with 50 or more full-time equivalent employees — compliance means more than just offering health insurance. It requires accurate tracking of employee hours to determine eligibility, properly offer coverage, and meet IRS reporting requirements. Failing to track hours precisely can expose companies to hefty penalties and compliance headaches.

If you’re navigating ACA compliance, a trusted partner like ACA-Track can make all the difference by simplifying and automating this complex process.


Understanding the Importance of Tracking Employee Hours Under ACA

Who Is an Applicable Large Employer (ALE)?

Under the ACA, ALEs are employers with 50 or more full-time employees or full-time equivalents (FTEs). The IRS calculates FTEs by combining hours worked by part-time and variable hour employees. This makes tracking all employee hours, including part-time and variable hour workers, crucial to accurately determine ALE status and eligibility for health insurance coverage.

What Constitutes a Full-Time Employee?

A full-time employee is someone who works an average of at least 30 hours per week or 130 hours per month. To comply with ACA requirements, employers must track hours worked carefully to identify which employees meet these thresholds over the applicable measurement periods.

Why Is Tracking Part-Time and Variable Hour Employees Essential?

Part-time and variable hour employees’ schedules fluctuate, which means employers must monitor their actual hours worked during measurement periods to determine if they have crossed the full-time threshold. Without this data:

  • Employers cannot prove an employee worked fewer than 30 hours on average.

  • Employees may seek marketplace subsidies unfairly.

  • Employers risk shared responsibility penalties if coverage was not offered when legally required.

Consequences of Not Tracking Hours Accurately

Failure to track and document employee hours leads to compliance risks including:

  • Penalties for failing to offer coverage to eligible employees.

  • IRS Letter 226-J penalty notices, demanding corrective action and penalty payments.

  • Increased audit risk and potential fines, sometimes reaching thousands of dollars per employee per month.


How ACA-Track Makes Employee Hours Tracking and ACA Compliance Easy

Tracking employee hours is complex due to variable schedules, multiple employee types, and the intricacies of ACA rules. ACA-Track offers a comprehensive, user-friendly solution to streamline this process.

1. Collect – Comprehensive Hours Data

ACA-Track collects actual hours worked for all employee types — including full-time, part-time, variable hour, paraprofessional, and substitute employees — by integrating with:

  • Timekeeping systems

  • Manual timesheets

  • Automated time clocks

  • Mobile device entries

  • Payroll and HRIS platforms

This ensures a single source of truth for accurate hour tracking.

2. Monitor – Employee Eligibility Alerts

ACA-Track monitors employee eligibility thresholds in real time, providing advance alerts when employees approach or exceed full-time status. It tracks key employee events like waivers and leaves to maintain compliance with ACA measurement and stability periods.

3. Report – Accurate ACA Reporting

ACA-Track electronically generates and files IRS-required ACA forms:

  • 1094-C transmittal forms

  • 1095-C employee statements

It supports both federal and state reporting, performs monthly line code audits, fixes reporting errors, and files electronic XML submissions to the IRS. Plus, it keeps all ACA data organized for quick retrieval during audits or state exchange requests.


Key Features of ACA-Track That Ensure Compliance

  • Customizable Dashboards: View and sort ACA data exactly how you want.

  • Snapshot Summaries: Preserve ACA data views at specific points in time for audit trails.

  • Flexible Configuration: Customize measurement, administrative, and stability periods, as well as thresholds and waiver codes.

  • Data-Driven Analysis: Export data, apply filters, and receive color-coded warnings for data anomalies.

  • Secure Cloud Platform: SOC 2 Type 2 compliant, encrypted data, and secure HTTPS transmissions protect sensitive employee information.


Beyond Tracking: ACA Reporting and Penalties

What Data Is Needed for ACA Reporting?

Employers must collect and report detailed data, including:

  • Employee full-time or part-time status

  • Hours worked per measurement period

  • Insurance offers made and coverage accepted or waived

  • Hire, termination, and status change dates

  • Employer Identification Number (EIN) and IRS reporting authorization

This data often comes from payroll, HR, benefits, and finance departments — making centralized tracking critical.

Reporting Deadlines Employers Must Know

  • Employee 1095 forms due January 31 (with occasional IRS extensions).

  • Employer 1094 transmittal to the IRS due March 31 each year.

  • ALEs with 250+ employees must file electronically and obtain a Transmitter Control Code (TCC).

Penalties for Non-Compliance

Non-compliance can result in substantial penalties:

  • $50 to $270 per return for late filings, escalating if filings are very late or missing.

  • Shared Responsibility Payment of $2,000 per full-time employee if coverage is not offered.

  • Penalties can accumulate to hundreds of thousands or even millions for larger employers.


Who Should Manage ACA Compliance in Your Organization?

Because ACA data touches multiple departments, collaboration among HR, Payroll, Benefits, and Finance is essential. Many companies designate the Chief Financial Officer, HR Director, or Benefits Director to oversee compliance. Utilizing a dedicated ACA compliance service like ACA-Track can unify efforts and simplify the process.


Why Choose ACA-Track for Your ACA Compliance Needs?

ACA-Track offers a proven, affordable, and fully integrated ACA compliance solution tailored to the needs of businesses, organizations, and clients of any size. With a dedicated Client Success Advisor, ACA-Track supports you every step of the way — from hour tracking and eligibility monitoring to federal reporting and error resolution.

By choosing ACA-Track, employers can confidently navigate ACA complexities, reduce risk of penalties, and streamline employee health coverage compliance.


Ready to simplify your ACA compliance?

Explore how ACA-Track can help you collect, monitor, and report employee hours and ACA data with ease and accuracy.

Visit ACA-Track 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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