ACA reporting – Aegis Admin

ALE Determination

ALE (Applicable Large Employer) determination is based on the prior calendar year’s headcount and hours. If you provide your data in a clean, table-based format, we’ll complete the analysis at no charge.

Free ALE Check: No-cost if data is table-based (e.g., Excel with labeled columns).
Prior-Year Rule: ALE status for a given year is determined using the previous year’s data.
Exceptions & Special Cases: Newly formed employers, mergers, acquisitions, and divestitures follow special rules (see Federal Register guidance below).
Methodology: Analysis follows the IRS framework for determining ALE status.

Helpful references:

IRS Example (FTE Calculation)

Employer has 40 full-time employees for each month of the year.
Employer also has 20 part-time employees, each working 60 hours per month.
Part-time hours per month total 1,200 (20 × 60).
1,200 ÷ 120 = 10 full-time equivalents (FTEs).
Annual totals: 480 full-time (40 × 12) + 120 FTE (10 × 12) = 600.
600 ÷ 12 = 50 average full-time + FTE → employer is an ALE for the following year.

(Adapted from IRS example for clarity.)

Typical ACA Reporting Timeline (for 2025 Coverage Filed in 2026)

Q3–Q4 2025: Collect employer-level info and complete intake/implementation questions.
Dec 2025–Jan 2026: Gather all processing data (census, enrollment, payroll/hours).
Late Jan–Feb 2026: Configure, code, QA, and finalize forms for review and sign-off.
Mar 2, 2026: Furnish 1095-C statements to employees (automatic 30-day extension of Jan 31).
Mar 31, 2026: IRS electronic filing deadline for 1094-C/1095-C.
April 2026: Submit any post-acknowledgment corrections as needed.
Year-Round: Support for back filings and assistance with IRS letters/penalties.

Penalties Overview

Employer Shared Responsibility (IRC §4980H)

§4980H(a) “Sledgehammer”: Failure to offer MEC to ≥95% of full-time employees (per EIN). Based on full-time count minus 30.
§4980H(b) “Tack hammer”: Offer not affordable or lacks MV to one or more full-time employees; assessed per impacted employee who receives a PTC.

Indexed penalty amounts

Calendar year 2025: §4980H(a) $2,900 (≈ $241.67/mo); §4980H(b) $4,350 (≈ $362.50/mo).
Calendar year 2026: §4980H(a) $3,340; §4980H(b) $5,010.

Amounts are set annually by IRS guidance and subject to change.

Information Return Penalties (IRC §§6721/6722)

For 2025 filings: up to $330 per return/statement; $660 for intentional disregard.
Tiered amounts may apply if corrected within 30 days or by Aug 1.
Notice 972CG: IRS notice used to assess information return penalties.
Common triggers: Late/incorrect 1094/1095s, failure to e-file when required, name/SSN mismatches, incomplete TIN solicitations.
Best practices: Early data validation, automated checks, and a documented corrections workflow.

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Have questions about ALE status, coding, or state filing? Send us a note and we’ll follow up with next steps.