Filing & ReportingAnnual
ACA ALE Determination & Affordability Analysis
IRC § 4980H; ACA Employer Shared Responsibility
Employer/broker must determine ALE status annually (50+ FTEs including FTE equivalents), select affordability safe harbor (W-2, Rate of Pay, or FPL), verify lowest-cost option meets MV and affordability threshold. Drives 1094-C/1095-C reporting and penalty exposure.
ResponsibleBroker
Deliver ToInternal compliance; informs 1094-C/1095-C reporting
Legal timingAnnually before plan year; ALE status determined based on prior year FTE count
Our targetFour months before the plan year starts, so the analysis lands before renewal decisions. This is our recommended timing, not a legal deadline for every plan. The legal timing is above.
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