ACA Reporting — what happens when we guess. (ScreenCast 04)

Summary.  In today’s ScreenCast 04 we  address some of the reporting and compliance problems that arise when employers aren’t quite ready to identify all of their ACA full time employees.


  • Some employers are pretty sure they will satisfy the 70% test required under ACA Employer Shared Responsibility rules for 2015. Employers in this boat have developed some imprecise methodology for identifying their ACA full time employees. In some cases they might be over-reporting their part time employees as full time employees.
  • Last week Melinda Maher and Bob Seng discussed some of the questions that pop up when an employer simply reports part-time employees as ACA full-time employees. You can find that discussion here. (ScreenCast 02).
  • Today’s ScreenCast attempts to answer some of those questions and describe the risk that comes with “punting” and simply putting part time employees (who receive offers of coverage) in the ACA full time category.

Bob Seng

With plenty of experience in private practice and as an Assistant General Counsel for Pay & Benefits in a Fortune 50 Company, Bob understands that employee benefits law isn’t for everyone. That’s why he takes pride in listening carefully and responding with clear answers and advice that can be followed by busy clients.

Melinda Maher

Melinda is a Partner in the Benefits & Compensation practice group. Her practice focuses on employee health and welfare plans. Her experience includes working with entities involved with health care on compliance with ERISA, COBRA, HIPAA, Medicare Secondary Payer rules, Federal and State health care mandates, and the Patient Protection and Affordable Care Act (Health Care Reform).

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