Dashboard
The operations home for one question — where are we in this tax year? KPI tiles, Essential Insights and quick links to Execute, Employees and the IRS or state Review desk. It reads; it never executes.
ACA Compliance: One Catalog, Twelve Monthly Facts, One Frozen Report Run
Catalog → monthly facts → report run. A consultant builds the rulebook once a year, the engine writes the facts every month, and operations executes, locks, reviews, approves and files — inside SAP-native benefits administration.
Most ACA reporting is a spreadsheet fed by exports and reconciled in January. Benefits Reimagined replaces it with three layers that stay in sync: the employer identity and IRS rulebook a consultant maintains; one governed row per employee per month with hours, full-time status, offer, contribution, Line 14/15/16 codes and the rule behind each; and a report run that freezes those rows into Forms 1094-C and 1095-C, then carries lock, review, approval, transmission, correction and print stamps for the six years an assessment can reach back.
Consultant catalog · consistency checkMonthly & look-back measurementW-2 · Rate of pay · FPL safe harbors1094-C / 1095-C · IRS AIRState packets · Print · Penalties
Reimagining ACA Compliance
"A consultant first builds the employer identity and IRS rulebook. Each month the engine writes living facts for every employee. Once a year — or on correction — operations freezes those facts into a report run, generates the 1094-C and 1095-C, locks the run, reviews, approves, and either queues XML for the IRS and the states or prints forms. Penalties are calculated on the monthly facts. Nothing in this module enrolls anyone, and nothing goes to the IRS because a button was clicked."
Configure the CatalogConsultants: ALE, tax company, measurement, Lines 14–16, Annual IRS ConfigurationWrite the Monthly FactsOperations: hours → class → look-back → offer → codes, every monthExecute the Report RunFreeze a run: 1094-C, 1095-C, employee packets, pending reasonsTransmit · IRS & StateLock · review · approve · transmit · corrections — flags on the runPrint & PenaltiesQueue employee copies; forecast and review §4980H exposure
3layers that stay in sync — the catalog consultants own, the monthly facts the engine writes, the report run operations files
12governed rows per employee per year — hours, status, offer, contribution, codes and penalty flag, each with the rule that set it
7pre-flight readiness sections checked before any run, each failure deep-linked to the catalog screen that fixes it
1authoritative 1094-C per ALE group — every member, every entity, every HRIS, transmitted once
The Working Flow — Who Works Where, in Order
One configuration workspace for consultants, then nine operations screens in the order a tax year actually runs. Rows shaded amber are the two places where “done” means “queued and logged” — the page says so, and so does the product.
| # | Screen | Who | What they do |
|---|---|---|---|
| 1 | ACA configuration workspace | Functional consultant | Build the catalog in order — addresses and global companies with EIN; safe harbors, look-back methods and assignment; plan MEC/MV characteristics; employee class and non-assessment rules; Line 14 → 15 → 16 and ZIP rule; tax company with ALE group and authoritative transmitter; ALE reporting and transmitting maps for the year; the Annual IRS Configuration; IRS connection, print provider and state reciprocity. Then run the consistency check. |
| 2 | Dashboard | ACA operations | Ask “where are we in this tax year?” — KPI tiles, Essential Insights and quick links to Execute, Employees and the IRS or state Review desk. The dashboard never executes a report. |
| 3 | Data · Employees | ACA operations | Run the monthly calculation for a population (up to ten in the foreground; more as a batch), then filter the living file for missing look-back or missing safe harbor, fix the catalog and re-run only those people. Open an employee for twelve months of detail. |
| 4 | Data · Wages & Time · Benefit Coverages | ACA operations · payroll | Inspect the feeds the engine reads — payroll wages and hours in unmatched, anomaly, duplicate and ready views; medical plans, options and their MEC/MV characteristics; dependent coverages. Read-only: elections are never changed here. |
| 5 | ACA Report · New ACA (Execute) | ACA operations | Choose the tax year, an employee scope or a filing company, Original or Correction, and optional state destinations. Read the seven-section pre-flight, the affordability card, the penalty-risk forecast and IntelliSuggest; raise a support case if needed; then Run. |
| 6 | Executed ACA → Employees → Detail · 1094-C · 1095-C | ACA operations | Browse every run, open its employees, read each packet's timeline, monthly grid, Line 14/15/16, measurement periods, audit and penalties; view the forms, generate PDF or XML; lock a completed run so nothing edits the frozen packet. |
| 7 | Transmission (IRS) · Review → Approve → Transmit → Corrections | Compliance lead | Review lists locked runs; Approve or Reject; Transmit packages per-employee XML and writes submission logs; Corrections lists transmitted runs with employees flagged for re-run. The AIR upload is its own audited action, Test before Production. |
| 8 | Transmission (State) | Compliance lead | The same four desks for California, New Jersey, Rhode Island and the District of Columbia packets, tagged for the state, with a state-deadline bar and company filter. Same XML and log path as federal. |
| 9 | Printing · Review → Print | ACA operations · mailroom | Queue reviewed runs for employee copies and track print status per run. Queuing sets the print flag and writes the print log; the vendor hand-off is the next step on the roadmap, so Mailroom hears “queued”, not “sent”. |
| 10 | ACA Report · Penalties | Compliance lead · finance | Open penalty executions and the penalized employees behind them — no coverage, no minimum value, not affordable — by month as §4980H(a) or (b). Penalty runs are kept off the lock and review desks by policy. |
2026 Filing Facts the Annual IRS Configuration Holds
Penalty amounts, the affordability percentage, full-time thresholds and the AIR schema version change every year. In Benefits Reimagined they live in the Annual IRS Configuration for each tax year — a run cannot start without it, and the forecast, the codes and the readiness scan all read from it.
§4980H(a) · 2026$3,340per full-time employee (minus the first 30) when coverage is not offered to at least 95% of full-time employees
§4980H(b) · 2026$5,010per full-time employee who receives a premium tax credit because the offer was unaffordable or lacked minimum value
Affordability · 20269.96%of household income, applied through a safe harbor; 2027 is already set at 10.22%
Furnish 1095-CMar 2, 2026tax-year-2025 statements to employees; January 31 for California's own furnishing deadline
E-file 1094-C / 1095-CMar 31, 2026to the IRS through AIR; 10 or more information returns in aggregate must be filed electronically
State reportingCA · NJ · RI · DCindividual-mandate reporting; Massachusetts uses Form 1099-HC and HIRD instead
Furnish on request30 dayspost a clear and conspicuous notice and provide 1095-C within 30 days of a request (Paperwork Burden Reduction Act)
Letter 226-J90 daysminimum response window, with a six-year limit on assessments — the evidence has to last that long
Figures from IRS Rev. Proc. 2025-25, 2025-26 and 2026-26, IRS Notice 2025-15, the Paperwork Burden Reduction Act and the Employer Reporting Improvement Act, as of September 2026. Informational only — confirm your filing position with counsel.
Three Layers, Six Stages
Follow an employer with three ALE members and a variable-hour plant from the catalog a consultant builds, through twelve monthly calculations, to the frozen report run, the transmission desks, the print queue and the penalty forecast — and see the same stages serve an entity that lives on another HRIS.
The catalog — the filing rulebook and employer identity, built first.
Before a single month is measured, a functional consultant builds the catalog in the ACA configuration workspace — a separate area from the operations desk. Six pages hold it: Organization Setup (global companies with EIN, address types, keys and addresses, the reporting and transmitting ALE maps, the time-sliced tax company); Health Plan Configuration (plan characteristics and their assignment to medical options); Eligibility & Measurement (employee classification, safe harbors, look-back methods and assignment, limited non-assessment); IRS Reporting Rules (Line 14, 15 and 16 and the ICHRA ZIP source); the Annual IRS Configuration; and Filing & Integrations (IRS connection, print provider, state filing). Later modules reference earlier ones, so the order matters — and a consistency check runs across all of it before the first employee does.
What the consultant maintains
- Employer identity — global company and EIN, ALE reporting and transmitting maps per tax year, a time-sliced tax company with ALE group and an authoritative transmitter
- Measurement — W-2, rate-of-pay and FPL safe harbors with a default; standard and initial measurement, administrative and stability periods, rolling or fixed; class rules with 25 criteria; non-assessment rules that override the year's defaults
- Coverage quality — MEC, minimum-value and self-insured characteristics assigned to plans, options and cost variants with effective dates; a characteristic alone drives nothing, the assignment does
- IRS rules and the year — Line 14 offer codes, Line 15 contribution display, Line 16 relief codes, ZIP source; then the Annual IRS Configuration: measurement method, full-time hours, affordability %, penalty amounts, defaults, schema version
Why it matters
A run cannot start without the year's Annual IRS Configuration — there is no fallback to last year's thresholds. The rulebook is a gate, not a suggestion.
The runtime chain every employee must satisfy — company code → ALE reporting map for the year → tax company → global company and address — is what the consistency check and the pre-flight scan both walk.
Monthly facts — the living file, and the feeds it reads.
The Data menu is not the IRS packet; it is the living file and its inputs. Employees shows one row per employee per month — hours of service, full-time flag, measurement method and calculation status — with a modal to run the monthly calculation for a population (ten or fewer in the foreground, more as the monthly batch) and filters for missing look-back or missing safe harbor. The engine behind it reads payroll hours, classifies the employee, decides new hire versus existing, applies look-back, non-assessment, full-time, coverage, penalty and line-code logic in turn, and writes the facts plus an audit row naming the configuration codes that fired. Wages & Time and Benefit Coverages show what it read: payroll wages and hours in unmatched, anomaly, duplicate and ready views, and the medical plans, options, characteristics and dependent coverages enrollment already holds.
What a month records
- Calculation — hours of service, full-time flag, eligible flag, monthly or look-back method, status and the job that wrote it
- Measurement — look-back method, average hours, measurement and stability dates, stage, expected full-time, coverage effective date, non-assessment type and dates
- Coverage — offered, accepted or waived; level; MEC, MV, affordable; safe harbor used; employee contribution; ICHRA and ZIP; COBRA, post-employment, self-insured
- Audit and penalty — which Line 14/15/16, look-back, non-assessment, ZIP and safe-harbor codes produced the values; §4980H(a) or (b) at month grain
Why it matters
Full-time status locked in a stability period cannot flip because one month's hours dipped — the offer and the penalty are judged consistently, and the reason is on the row.
The monthly job never creates a report run. Operations can fix the catalog and re-run January for three people without anything being filed by accident.
Execute — freeze the year into a run you can defend.
On New ACA, operations picks the tax year, then the population — an employee scope built with the shared selection tool, or a whole filing company; switching one clears the other. Original or Correction (a correction needs a source run with employees flagged for it). Optional state destinations from the reciprocity catalog. A seven-section pre-flight readiness scan deep-links every failure to the catalog screen that fixes it; an affordability card, a penalty-risk forecast, a checklist and IntelliSuggest sit beside it, and a support case can be raised into BR Resolve with the run attached. Run: zero people blocks; more than ten hands off to the execution batch on a shared run number; ten or fewer run now. The engine resolves each employee's ALE, creates the run, loads the year's configuration, freezes each person's months into a snapshot — gap-filling missing months — builds the 1095-C from that snapshot with no live re-scoring, then the 1094-C per tax company, and stamps the timeline.
What the run produces
- A run header — period, population, transmitting ALE, status, counts, and every lifecycle flag from lock to print
- One employee packet per person — coverage quality, safe harbor, correction and state flags, PDF and XML locations, status and error reason
- Structured forms — Form 1095-C with covered individuals for self-insured plans; Form 1094-C employer and monthly summaries; PDF and XML from the same tables
- Pending rows that name the reason — an employee whose company has no ALE map for the year, a missing state, no assignable health-plan characteristics — so the run finishes and the fix is specific
Why it matters
Employees are never re-scored at filing time — the 1095-C is the monthly evidence, frozen, not a fresh calculation nobody can reproduce.
A run can finish successfully and still show Pending: it means some employees need a catalog fix, not that the run failed. The Executed ACA list shows the reason per person.
Transmit — lock, review, approve, transmit, correct: federal and state.
Transmission is a pipeline of flags on the run, and each desk is a filter on those flags rather than a to-do list someone keeps. From Executed ACA a completed, non-penalty run is locked. IRS Review lists locked runs not yet reviewed; Approve lists reviewed runs not yet decided, and records approved, rejected or undecided; Transmit lists approved runs and, on Transmit, packages per-employee XML and writes a submission log for the run and for every person — as a batch when more than ten. The IRS AIR upload is a separate, deliberate action that needs the IRS connection and certificate and a successful Test before Production; its receipt and validation status land on the run. Corrections lists transmitted runs whose employees were flagged for correction and sends operations back to Execute as a Correction. The state desks repeat the four steps for California, New Jersey, Rhode Island and the District of Columbia, tagged for the state, with a deadline bar and a company filter.
What the desks enforce
- Lock before review; review before approval; approval before transmit — the list on each desk is the flag filter
- Rejection returns the run toward review with its reason; unlock is explicit and logged; per-employee transmit is possible for a person with no log yet
- Corrections touch only the flagged employees and bump the version; the original packet stays on record; the correction is transmitted as a correction
- State packets share the federal XML and log path, tagged for the state — one workflow, two destinations
Why it matters
Finance hears “transmitted” only when every latest employee record has a submission log — never when a button was clicked. The AIR receipt is a second, later fact on the same run.
Transmitter control code, certificate and endpoints live in the IRS connection catalog and are exposed to assistants only as yes/no readiness — never as values.
Print & penalties — furnish the copies, forecast the exposure.
Two smaller desks close the loop. Print Review lists reviewed runs not yet queued; queuing marks the run for printing and writes a print log with who queued it; the Print screen shows status per run and opens its employees. It is a queue and a log — the print vendor's own hand-off is the next step on the roadmap, so the page says “queued”, not “sent”. Penalties lists penalty executions and, behind each, the penalized employees with the type — no coverage, no minimum value, not affordable — and the month-level §4980H(a) or (b) classification; the Execute page shows the forecast before you run. Employee copies can also be furnished on request under the Paperwork Burden Reduction Act, generated from the same frozen run.
What these desks make explicit
- Print queue with status — pending, completed, failed — per run, attributed to the person who queued it
- Penalty type per run and per employee, and the month grain behind it, calculated on the monthly facts from the year's configured amounts
- Penalty runs are kept off the lock and review desks by policy — they inform the fix, they are not a packet to file
- On-request furnishing from the same run: the statement an employee asks for is the one the IRS received
Why it matters
The mailroom and Finance read the same flags operations set — nobody has to remember whether the copies went out or the penalty was forecast.
Summary tiles on the list pages are illustrative in the current release; the official numbers come from the KPI, error-triage and acceptance-forecast services the Dashboard reads.
SAP-native. Ready for every HRIS your entities run.
On SAP SuccessFactors Employee Central and Employee Central Payroll, the hours, wages, job data and elections the monthly engine needs are already in Benefits Reimagined in real time. For an acquired plant on Workday, a division on UKG, or payroll on ADP, Dayforce or Paycom, the HRIS Sync control plane fills the same canonical fields — hours of service, W-2 wages, company code, employment status — and IntelliMap shortens the mapping. The catalog never sees a vendor field name: company code → ALE reporting map → tax company works the same whichever system supplied the code, so one ALE group with entities on three systems files one authoritative 1094-C.
What stays the same across systems
- One catalog, one monthly engine, one report run for every entity in the tenant
- Payroll wages and time land in one place with unmatched, anomaly, duplicate and ready views before the month runs
- ACA reads elections and never writes them — enrollment stays where it is, on whichever HRIS
- An employee's statement question opens in BR Resolve with that person's 1095-C in view, whichever HRIS is behind it
Why it matters
A carve-out, a merger or a payroll change should not mean a second ACA vendor and a second reconciliation.
Runs on SAP BTP or AWS, with SAP HANA or PostgreSQL — the same platform as enrollment, billing and analytics.
The Rules of the Run — What the System Enforces
Nine rules a benefits administrator should know before the first execution. Each is enforced by the engine or by the desks, not by a checklist someone remembers — and each says plainly what the platform does and does not do.
| Rule | What the system does | What it means for you |
|---|---|---|
| Configure before you run | The run loads the year's Annual IRS Configuration first. Missing or inactive stops the run — there is no fallback to last year. | Consultants finish the catalog and the consistency check before operations opens Execute. |
| Every employee needs a chain | Company code → ALE reporting map for the year → tax company → global company and address, effective on the month's mid-date. | An unmapped employee becomes Pending with the reason; the run still finishes and names the fix. |
| One authoritative transmitter | The ALE group must name which member files the authoritative 1094-C. | Aggregated groups file once, correctly, with every member listed. |
| Monthly facts are not a 1095-C | The Employees list is the living file; forms exist only after Execute creates a run number. | Fix and re-run a month for three people without filing anything by accident. |
| Ten now, more as a batch | Monthly calculation, execution and transmission run in the foreground for up to ten people and as batch jobs above that — same run number. | Large populations do not time out; small pilots come back while you watch. |
| Lock before Review | Review lists only locked runs not yet reviewed; Approve records approved, rejected or undecided. | The desks are filters on the run's flags, so nothing is skipped and every step is attributed. |
| Transmit ≠ upload | Transmit packages XML and writes submission logs; the AIR upload is its own action, Test before Production, receipt stored on the run. | Finance is told “transmitted” only when the logs exist, and “accepted” only when the IRS says so. |
| Print is a queue | Print Review sets the print flag and writes the print log; the vendor hand-off is roadmap. | Mailroom reads the same status operations set — “queued”, not “sent”. |
| ACA never enrolls anyone | The module reads plan characteristics and payroll hours and writes facts, snapshots and forms — never an election. | A wrong dental election is an enrollment fix; ACA only reported the medical offer the catalog described. |
Nine Screens in the ACA Operations Workspace
The sidebar is fixed — ACA Report, Data, Transmission and Printing — and role-based access decides who can act on each page. Every screen reads the same three layers; the amber tags mark the two hand-offs that are on the roadmap rather than in the release.
New ACA · Execute
Tax year, employee scope or filing company, Original or Correction, state destinations; seven-section pre-flight with deep links, affordability card, penalty-risk forecast, checklist, IntelliSuggest, support case; then the run and its timeline.
Executed ACA & Employee Packets
Every run with status, counts and flags; lock and unlock; error and correction re-run; the employees behind a run with MEC, MV, affordable and status; each packet's timeline, monthly grid, Lines 14/15/16, measurement periods, audit and penalties.
Forms 1094-C & 1095-C
Read-only IRS layouts built from the structured form tables of the frozen run — Part I employer block, Part II monthly codes, Part III covered individuals — with PDF and XML from the same record and form insights beside them.
Employees · Monthly Calculation
The living file: one row per employee per month, filters for missing look-back or safe harbor and named populations, a run-calculation modal with the ten-now-or-batch rule, and twelve months of detail per person.
Wages & Time · Benefit Coverages
What the engine reads: payroll wages and hours by period in unmatched, anomaly, duplicate and ready views; medical plans, options, MEC/MV characteristics and dependent coverages. Read-only — elections stay in enrollment.
Transmission · IRS & State
Four desks each — Review, Approve, Transmit, Corrections — as filters on the run's flags; XML packaging and submission logs on Transmit; the separate AIR upload with Test before Production; state packets tagged for CA · NJ · RI · DC with a deadline bar.
Printing
Print Review queues reviewed runs for employee copies and writes the print log; Print shows status per run and opens its employees. A queue with an audit trail today; the vendor API hand-off is next.
Penalties
Penalty executions and the penalized employees behind each — no coverage, no minimum value, not affordable — by month as §4980H(a) or (b), from the year's configured amounts; kept off the lock and review desks by policy.
Spreadsheets & Bolt-On ACA Vendors vs. Embedded Compliance
Most ACA reporting is a separate product fed by exports. Here is what changes when the catalog, the monthly facts and the report run are the benefits record.
| Moment | Export-and-file ACA vendor | Benefits Reimagined ACA |
|---|---|---|
| Where the rulebook lives | A consultant's spreadsheet and the vendor's onboarding form. | A catalog with effective dates, a consistency check and a per-year Annual IRS Configuration that gates the run. |
| Where the hours come from | A payroll export reformatted for the ACA vendor each quarter. | Payroll wages and time already in the platform — reviewed for unmatched, anomaly and duplicate rows before the month runs. |
| When full-time is decided | At year end, from a spreadsheet of averages. | Every month, with stability-period lock, non-assessment periods and the method recorded. |
| Offer evidence | Carrier enrollment file cross-referenced by hand. | The employee's own election — offered, accepted or waived — with MEC and MV from plan characteristics. |
| The 1095-C | Generated 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 structured tables. |
| “Did it go to the IRS?” | Someone checks the vendor portal. | Two facts on the run: Transmitted when every employee log exists; accepted when the AIR receipt is stored. |
| An IRS correction letter | Find the file, find who built it, rebuild the month. | Corrections desk lists the run; re-run only the flagged employees as a new version; original kept. |
| Three entities on two HRIS platforms | Two vendors, or two uploads and one very careful analyst. | One ALE group, one catalog — HRIS Sync fills the same fields; one authoritative 1094-C. |
| An auditor asks why | An email thread and a former colleague's memory. | The audit row: rule, version, configuration year, safe harbor, timestamp — six years back. |
Athena Admin — on every ACA screen
Ask Why a Code Is 2F Before the IRS Asks
A floating administrator assistant lives on every page of the ACA operations workspace — not the employee enrollment Athena. It knows the catalog, the IRS rules, the measurement periods and the penalty logic; explains any employee-month in plain language; can answer from your data on an allow-list of employee fields; and offers chips that jump to the exact configuration or operations screen that changes the answer. Credential and connection values are never in scope — the IRS connection appears only as ready or not. It drafts; a person configures, runs and files.
- "Why is Alex 2F in August?" — the offer rule, the safe harbor that failed, the contribution and the percentage it was tested against
- "Who fails affordability if the hourly rate changes on 10/1?" — a forecast from the monthly facts, listed by tax company
- "Is 2026 ready to execute?" — the seven readiness sections in words, with a chip to each red one
- "Which employees are Pending in run 2025-O and why?" — missing ALE map, missing state, no health-plan characteristics — with the fix
- "Has 2025-O actually reached the IRS?" — Transmitted (logs exist) versus accepted (AIR receipt stored), read from the run's own flags
Why did Plant 2 hourly employees get 2F in August?
Athena · from August monthly factsThree employees in tax company 1000 moved to pay grade H3 on 8/1. Their offer still carries 1E — MEC and minimum value to employee, spouse and dependents — but the rate-of-pay safe harbor test failed: $142.10 a month exceeds 9.96% of the new hourly rate × 130 hours. Line 16 therefore shows 2F (rate of pay is the configured default safe harbor for tax company 1000). July was 2C for all three. Nothing has been filed — this is the monthly file, not a report run.
Sources: Monthly audit · 2026-08 · offer rule 1E · safe harbor ROP · Annual IRS Configuration 2026 · 9.96%
Open the three employeesOpen Safe Harbor Methods
If we switch that group to the FPL safe harbor, does August clear?
AthenaYes for all three: the FPL safe harbor tests $142.10 against 9.96% of the federal poverty line ÷ 12, which is within the threshold for 2026. Changing the default safe harbor for tax company 1000 from 8/1 and re-running August for those employees would restore 2C. I've drafted the configuration change as a request for the compliance lead to approve — I do not change catalogs myself.
Review the draft changeRe-run August for 3 employees
Ask about any employee-month, run, code or rule…
What the ACA Compliance System Changes
From reactive to continuous compliance
Eligibility and risk are monitored year-round: twelve governed months per employee, not one reconciliation in January.
From spreadsheets to a catalog
ACA rules — measurement, safe harbors, line codes, non-assessment, the year's thresholds — are applied from catalogs a consultant maintains and a consistency check validates.
From assumptions to evidence
Every decision is documented and defensible: the rule, the version and the configuration year sit on the employee-month; the run freezes them.
From year-end chaos to a gated run
Reporting is prepared continuously; the run freezes what the months already proved, and the Annual IRS Configuration and readiness scan gate it.
From hidden risk to a named reason
Issues surface early — a failed safe harbor, a missing ALE map, a missing state — as Pending rows with the fix one link away.
From inboxes to flags on the run
Lock, review, approve, transmit, correct and print are desks filtered by the run's own flags — attributed, timestamped, and honest about what has actually reached the IRS.
Five Stories a Tax Year Tells
The same three layers, told the way administrators live them. Consultants own the catalog, operations owns the facts and the runs, compliance leads own the desks, and employees see only their own statement — the same roles whether the tenant is one employer, an aggregated ALE group or a shared-services center filing for many.
- Standing up 2026 filing — addresses and EIN; safe harbor, look-back and class rules; MEC/MV on the medical plans; Lines 14–16 and the ZIP rule; tax company with ALE group and transmitter; ALE maps for 2026; the Annual IRS Configuration; the IRS Test connection; the consistency check. Then prove it: monthly facts for one pilot employee, an Original run for that person, open the 1095-C.
- January close — payroll lands; the monthly batch writes January's facts; operations filters for missing look-back or safe harbor, fixes the catalog and re-runs those people. No run number exists yet — nothing to lock or transmit.
- Annual original filing — Execute by scope or filing company, Original, optional states; pre-flight green or Pending rows accepted; ten or fewer run now, more wait for the batch; Executed ACA → lock → IRS Review → Approve → Transmit (XML and logs); a designated user runs the AIR upload on Test, then Production; Print Review queues the employee copies.
- The IRS asks for a correction — the response flags employees; the Corrections desk shows the run; operations opens Execute as a Correction on the same run number; the engine reprocesses only the flagged people, bumps the version and marks the snapshot corrected; the new packet is locked, reviewed and transmitted as a correction.
- An employee has no ALE map — Alex's company code is missing from the year's reporting map; Execute writes Alex as Pending with that reason and the run finishes; the consultant adds the map and re-runs Alex — or a correction if already filed. Alex's enrollment is untouched.
Build the Catalog. Write the Months. Freeze the Run. Prove It for Six Years.
Bring last year's 1095-C population and this year's payroll hours. We'll stand up the catalog for one tax company, run the monthly calculation on a sample, show you the safe-harbor result per employee, freeze a report run, and walk the same packet through lock, review, approval and the IRS Test connection.
Catalog · consistency checkMonthly & look-back methods3 safe harborsIRS AIR · Test then ProductionCA · NJ · RI · DC packets
ACA Compliance FAQs
Meeting the federal employer-shared-responsibility requirements: tracking which employees are full-time under IRS rules, offering affordable minimum-value coverage to them, reporting those offers on Forms 1094-C and 1095-C, furnishing 1095-C statements to employees, and keeping the documentation that shows how each decision was made. Benefits Reimagined does this inside benefits administration, so the same elections and payroll hours that run enrollment run compliance.
As three layers that must stay in sync. The catalog — the filing rulebook and employer identity a functional consultant maintains in the ACA configuration workspace. The monthly facts — one governed row per employee per tax year per month that the engine writes: hours, full-time status, offer, contribution and codes. The report run — a frozen packet, identified by a run number, that operations executes, locks, reviews, approves and transmits or prints. Consultants own the first; operations runs the other two.
A report run freezes every in-scope employee's monthly facts into a snapshot under one run number, then builds each Form 1095-C from that snapshot and a Form 1094-C for each tax company. Nothing is re-scored at filing time, so what the IRS receives is exactly the evidence the months already recorded. Lock, review, approval, transmission, correction and print status are all stamps on that run.
Applicable Large Employers — 50 or more full-time employees or equivalents — and especially organizations with variable-hour, seasonal or multi-entity workforces, where look-back measurement, controlled-group reporting and correction cycles are hard to manage in spreadsheets.
From average hours of service using either the monthly measurement method or the look-back method the IRS defines. Benefits Reimagined evaluates every employee every month: hours from payroll, classification as full-time, part-time or new, the measurement, administrative and stability periods that apply, and any limited non-assessment period — then locks full-time status for the stability period so offers and penalties are judged consistently.
Form 1094-C, the employer transmittal, and Form 1095-C, one statement per full-time employee (and per covered individual for self-insured plans). Benefits Reimagined generates both from a frozen report run, produces the PDF and the IRS XML from the same structured record, and tracks the transmittal, receipt and correction status of each run.
For tax year 2025, 1095-C statements are due to employees by March 2, 2026 and the 1094-C/1095-C e-file is due to the IRS by March 31, 2026. Employers filing 10 or more information returns in aggregate must file electronically. Thresholds and amounts are configured per tax year in the Annual IRS Configuration, so the dashboard shows what applies to the year you are filing.
For 2026 the §4980H(a) penalty is $3,340 per full-time employee (after the first 30) when no offer is made to at least 95% of full-time employees, and the §4980H(b) penalty is $5,010 per full-time employee who receives a premium tax credit because the offer was unaffordable or lacked minimum value. Benefits Reimagined stores the year's amounts in the Annual IRS Configuration and forecasts exposure from the monthly facts before you execute a run.
The 2026 affordability threshold is 9.96% of household income (10.22% for 2027). Because employers do not know household income, the IRS allows three safe harbors: Form W-2 wages, rate of pay, and the federal poverty line. Benefits Reimagined maintains all three as configurable methods, sets a default per tax company and per year, and records which method justified each month's Line 16 code.
Transmit packages the per-employee XML and writes a submission log for the run and for every employee — that is the audited queue. The IRS AIR upload itself is a separate, deliberate action that requires the IRS connection and certificate to be configured and a successful Test submission before Production. The run shows Transmitted only when every latest employee record has its log, and the receipt and validation status are stored on the run once AIR responds. Printing works the same way: Print Review queues copies and logs the request.
California, New Jersey, Rhode Island and the District of Columbia require employer reporting for their individual mandates, and Massachusetts has its own Form 1099-HC and HIRD filings. Benefits Reimagined keeps a state reciprocity catalog with each state's form type, authority and dates, flags the employees who need a state record, and runs state packets through the same review, approve and transmit desks as the federal filing, tagged for the state.
Every month's full-time status, offer, contribution and relief code is stored with the rule that produced it, and every report run freezes those facts under a run number with lock, review, approval, transmission and correction stamps. When an IRS Letter 226-J or 5699 arrives — employers now have at least 90 days to respond — the evidence is a query, not a reconstruction.
Yes. ACA compliance is embedded directly within Benefits Reimagined, not managed separately: it reads the medical elections enrollment already holds and the hours and W-2 wages payroll already posts — and it never writes an election back. On SAP SuccessFactors Employee Central and Employee Central Payroll it runs in real time; for Workday, UKG, ADP, Dayforce, Paycom or any other HRIS the HRIS Sync control plane fills the same canonical fields, so one rulebook serves every entity.
The 1095-C Is the Receipt. The Twelve Months Are the Proof.
The catalog is the rulebook. The monthly facts are the living file. The report run is the IRS packet. Enrollment stays where it is — on SAP SuccessFactors today and on whichever HRIS your next entity brings.