What Is the Affordable Care Act Employer Mandate?

The Affordable Care Act (ACA) requires Applicable Large Employers (ALEs) — those with 50 or more full-time equivalent employees — to offer minimum essential health coverage to full-time employees and their dependents. Failure to comply can result in significant IRS penalties under the Employer Shared Responsibility provisions.

Key 2026 Reporting Deadlines

Employers must be aware of the following annual deadlines:

  • January 31: Deadline to furnish Form 1095-C to employees
  • February 28: Paper filing deadline for Forms 1094-C and 1095-C with the IRS
  • April 1: Electronic filing deadline (required for employers filing 10+ forms)

Missing these deadlines can trigger penalties of $310 or more per return, with no cap on annual penalties for intentional disregard.

Determining Full-Time Status: The Look-Back Method

One of the most complex aspects of ACA compliance is accurately classifying full-time versus part-time employees — especially for variable-hour and seasonal workers. The IRS permits use of the “look-back measurement method,” which allows employers to measure an employee’s hours over a defined period (3–12 months) to determine coverage eligibility.

Automated time tracking systems that integrate directly with ACA reporting tools eliminate the manual calculations that lead to costly classification errors.

Common ACA Compliance Mistakes

  • Failing to track hours for part-time and variable-hour employees accurately
  • Incorrectly determining ALE status for companies with seasonal fluctuations
  • Overlooking controlled group rules for related business entities
  • Submitting inaccurate or incomplete 1095-C codes
  • Missing the electronic filing threshold (now just 10 forms)

How CTR/NY’s Visual ACA Program Helps

CTR/NY’s Visual ACA Program automates the most complex parts of ACA compliance. It uses actual time and attendance data to perform look-back calculations, determine full-time/part-time status, assess ALE standing, and generate IRS-ready 1094-C and 1095-C forms — eliminating guesswork and dramatically reducing your compliance risk.

When your time and attendance system and ACA reporting tool share the same data, errors caused by manual re-entry disappear entirely. That integration is at the core of what we offer.

Next Steps

If you’re unsure whether your current system is capturing the data you need for ACA compliance, contact CTR/NY for a free consultation. Our team has helped hundreds of employers across New York and the surrounding region navigate ACA requirements without penalties.