Stay ACA & QMCSO Compliant — Filings, Orders and Notices on Time

The elections your employees make, the hours payroll posts and the orders that arrive in the mail are already in Benefits Reimagined. Compliance reads them: full-time status and offers for the ACA, qualification and enrollment for medical support orders, and the evidence behind both.

Most compliance failures are not judgment calls. They are a variable-hour employee nobody measured, a 1095-C built from a census that was already wrong, a National Medical Support Notice that sat in a mailroom past its 20 business days. Benefits Reimagined removes the export between the benefits record and the compliance record, so the deadline is met by the system that holds the facts. COBRA administration is a roadmap item and is shown on this page as such.

Monthly & look-back measurement 1094-C / 1095-C · IRS AIR NMSN Part A / Part B on the clock Order enrollment on order dates Compliance Framework checks COBRA · roadmap
ComplianceACA tax year 2026 · orders · facts through AugustReadiness 7 of 718,412Employees measured97.4%Full-time offered MEC + MV9Orders on the clock3Risks flagged this monthACA · August monthly calculationhours → full-time → offer → Line 14/15/16completeACA · Report run 2025 · Original1094-C ×3 · 1095-C ×17,904 · IRS AIRacceptedQMCSO · NMSN intake4 new notices · Part A due in 20 business dayson clockQMCSO · enrollment3 children enrolled on order dates · Part B sentcompleteCompliance Frameworkchecks run · evidence appended · calendar currentscannedACA · Plant 2 hourlyrate-of-pay safe harbor fails at 9.96% for 3 employeesact nowCompliance is a month-end fact, not a year-end scrambleEvery ACA employee-month and every medical support order carries the rule that produced itand the notice that went out — so an auditor's question is a query, not a reconstruction.Illustrative tenant · your plans, your populations, your numbers

Two Regulations Today, One Failure Mode

ACA and medical support orders fail the same way: the fact that triggers the obligation — hours worked, coverage offered, an order received — lives in one place, and the obligation is tracked in another. Every export between them is a place for an employee, or a child, to fall through. Benefits Reimagined keeps the trigger and the obligation on the same record, with the rule that connected them written down.

ACA

Full-time decided in January

Average hours calculated at year end from a payroll extract, so a variable-hour employee who crossed 130 hours in March gets a 1095-C code nobody can defend.

QMCSO

Orders handled as mail

A National Medical Support Notice arrives, is forwarded to whoever handles garnishments, and the employer’s 20-business-day response and the plan’s 40-business-day enrollment window run out in an inbox.

Both

Evidence that lives in an inbox

When Letter 226-J arrives, or a child support agency follows up, the answer is an email thread and a former colleague’s memory rather than a record.

$3,340 / $5,010 the 2026 §4980H(a) and (b) penalties per full-time employee — IRS figures, forecast from your monthly facts before you file
20 / 40 business days for the employer’s Part A response and the plan’s Part B enrollment response on a National Medical Support Notice
12 governed rows per employee per year — hours, status, offer, contribution, codes and penalty flag, each with the rule that set it
1 authoritative 1094-C per controlled group — every member, every entity, every HRIS, transmitted once

One Record, Four Obligations

Follow an employer through a compliance year: the ACA measured every month and filed once; medical support orders intaken, qualified and enrolled on the statutory clocks; the framework that checks everything else; and COBRA marked where it will join.

1

Measure the ACA every month, not every January

Each month the engine reads hours from payroll — SAP ECP or any 3rd-party payroll — classifies the employee under the monthly or look-back method, tests the offer for minimum essential coverage, minimum value and affordability under the safe harbor that applies, and writes the Line 14, 15 and 16 codes with the rule behind each. A failed safe harbor is flagged in the month it happens, while there is still time to fix the contribution.

Hoursfrom payrollFull-timelook-back · lockedOfferMEC · MV · harborCodesL14 · 15 · 16 + ruleCodesL14 · 15 · 16 + rule
2

File once from a frozen run, federal and state

When the year is ready, a readiness scan checks the configuration, the run freezes every employee’s monthly facts, and Forms 1094-C and 1095-C are built from that snapshot — PDF and IRS XML from the same record. Lock, review, approve and transmit are desks with named stamps; the IRS AIR upload is its own Test-then-Production action; corrections re-run only the flagged employees; state packets for California, New Jersey, Rhode Island and the District of Columbia follow the same path.

Readiness scan7 sections checked · each failure linked to its fixReport run frozen1094-C per ALE member · 1095-C per employee · PDF + XMLLock → review → approve → transmitIRS AIR: Test first, then Production · receipt on the runCorrections · states · printonly flagged employees re-run · CA · NJ · RI · DC · furnish on request
3

Intake, qualify and enroll medical support orders on the clock

A court order, agency order or National Medical Support Notice is intaken by an administrator with the order dates and the children named. Document-validity, fraud and pre-check engines store their results; a person passes or fails the order; qualification is approved in Workflow; and enrollment is a date-exact gate — NMSN reason, qualified order, event dates equal to order dates, verified child — with Part A and Part B responses generated and the 20- and 40-business-day clocks visible on every case.

Order receivedNMSN · day 0Part Aemployer · 20 bus. daysQualifiedworkflow approvalEnrolled · Part Bplan · 40 bus. daysEnrolled · Part Bplan · 40 bus. days
4

Check everything else on a calendar — and add COBRA when it ships

The Compliance Framework runs configured checks against the record and appends the evidence — a masked value and an integrity hash, never raw PHI — with a calendar for the rest of the year: 1095-C, RxDC on June 1, Form 5500 and PCORI on July 31, Medicare Part D notices on October 15, the gag-clause attestation on December 31. COBRA administration — qualifying events from the HR record, election notices, terminations by rule — is on the roadmap and will run on this same record; it is labelled as roadmap wherever it appears on this site.

Checksconfigured by consultants · run on a schedule · pass, fail, not applicableEvidenceappend-only · masked value + integrity hash · never raw PHICalendar1095-C · RxDC Jun 1 · 5500/PCORI Jul 31 · Part D Oct 15 · gag clause Dec 31COBRA · roadmapevents → notices → premiums → terminations, on this record

Year-End Compliance vs. Compliance on the Record

Six moments in a compliance year, and what changes when the trigger and the obligation share one record.

Moment The way it usually goes Benefits Reimagined
Deciding who is full-time At year end, from a spreadsheet of averages. Every month, with the measurement method, the stability lock and the rule recorded.
Testing affordability One safe harbor for everyone, checked at filing. Three safe harbors, default per tax company, tested per employee per month against the year’s percentage.
Building the 1095-C From a census upload; codes keyed or guessed. Frozen from the monthly snapshot; Line 14/15/16 from rules; PDF and XML from the same record.
An order arrives Forwarded to garnishments; the clock runs in an inbox. Intaken with its dates; 20- and 40-business-day clocks on the case; Part A and Part B drafted.
Enrolling the child Someone might refuse; someone might forget. A date-exact gate as a permitted election change, without regard to enrollment season.
An auditor asks why An email thread and a former colleague’s memory. A query: rule, version, decision, response and delivery on the employee-month and on the order.

What Changes When Compliance Reads the Benefits Record

From a year-end scramble

Twelve governed months per employee

Full-time status, offer, contribution and codes are decided every month with the rule behind them; the 1095-C is the evidence frozen, not a fresh calculation.

From an order in the mailroom

A case on the clock

Intake stamps the order dates; the 20- and 40-business-day windows count down on the case; nobody discovers the deadline afterwards.

From a guess at qualification

Engines that inform, a person who decides

Document validity, fraud and pre-check results are stored; an administrator passes or fails the order and Workflow approves it.

From enrollment someone might refuse

A date-exact gate the employee cannot block

The child is enrolled on the order dates as a permitted election change — without regard to enrollment season.

From one vendor per regulation

One platform, one rulebook, every entity

ACA and orders on the same record as enrollment and billing — for SuccessFactors entities and for the ones on any other HRIS.

From evidence in an inbox

An audit trail you can query

Rule, version, decision, response, delivery — on the employee-month and on the order, appended with an integrity hash.

Athena on the compliance desk

Ask Why Before the IRS or an Agency Asks

The compliance workspace has Athena for Admins. It answers help-first from the ACA configuration, the measurement periods and the order rules; with ‘Include employee data’ it looks up a case or an employee-month read-only and explains it in plain language. It drafts responses and configuration changes for approval — it never files, transmits, enrolls or claims to have re-run anything.

  • “Why is this employee 2F in August?” — the offer rule, the safe harbor that failed, the contribution and the percentage it was tested against
  • “Which orders run out of time this week?” — the cases by business days remaining, with the Part A or Part B response drafted
  • “Is 2026 ready to file?” — the seven readiness sections in words, with a link to each red one
  • “Show me everything on this order.” — intake, engine results, decision, responses, enrollment dates — the answer to the agency’s follow-up
How BR Intelligence works across modules
Athena Compliance · administrator
Anything at risk this week across ACA and the orders? Include employee data.
Athena · read-only lookup Two things. Orders: 9 are on the clock; 2 NMSNs received on the 3rd have Part A due in 6 business days and are still in intake because the children named don’t match any dependent on the employee records — both need an administrator to add the children before the pre-check can run. ACA: three Plant 2 hourly employees fail the rate-of-pay safe harbor for August after the pay-grade change; the exposure is 4980H(b) only, and nothing has been filed.
Open the 2 orders Show the 3 employees
Draft the Part A responses and tell me the fastest fix for the three.
Athena Part A drafted for both orders from the notice data, held until the children are added and the pre-check passes — the drafts are with the compliance lead. For the three employees, switching tax company 1000 to the federal-poverty-line safe harbor from 8/1 clears all three for August; I have prepared the configuration change for approval in Workflow. I don’t change catalogs, send responses or enroll anyone myself.
Review the Part A drafts Review the safe-harbor change
Ask about any employee-month, order, notice or run…

See Your Exposure Before You Have to Explain It

Bring last year’s 1095-C population, this year’s payroll hours and one medical support order you received recently. In the 45-minute walkthrough we will run a monthly ACA calculation on a sample, show the safe-harbor result per employee, and walk the order from intake to enrollment with the clocks running.

Rule on every code Evidence appended, never edited Engines inform · people decide Athena never files or enrolls COBRA labelled roadmap

Stay Compliant FAQs

The Filing Is the Receipt. The Record Is the Proof.

ACA and medical support order compliance that lives where the elections, the hours and the dependents already are — on SAP SuccessFactors today and on whichever HRIS your next entity brings.