Under the Affordable Care Act (ACA), an employer is an Applicable Large Employer (ALE) and subject to the Employer Shared Responsibility requirements if it employed, on average, at least 50 full-time or full-time equivalent employees (FTEs) during the prior calendar year.
For example, an employer’s size calculated over calendar 2016 determines the employer’s ACA obligations for calendar year 2017, which is reported for the first time in the beginning of 2018 (forms 1095-C and 1094-C).
Employer’s that determine they have 50 or more FTEs for the first time at the end of 2016 must comply with the employer mandate requirements as of January 1, 2017; however, there is transition relief provided until April 1, 2017. During the transition relief months employers should ensure individuals who are currently full time employees (30+ hours / week) are offered applicable (affordable and minimum value) group health coverage by April 1, 2017.
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