ACA strategy from people who file every season.
Aggregated ALE analysis, measurement methodology, affordability strategy, retrospective modeling. The thinking behind the filing — equal parts consultative and operational.
Five services. One strategic posture.
Advisory work isn’t just answering questions. It’s the structural analysis that determines how every subsequent filing season goes. Get the controlled group wrong, and three years of filings are exposed. Pick the wrong measurement method, and variable-hour employees become a penalty surface. The advisory engagement is consultative when the question is strategic and operational when the question is computational — and most engagements are both.
Affordability Testing
W-2, Rate of Pay, and Federal Poverty Line safe harbor selection, optimized per employee.
The IRS lets you pick from three affordability safe harbors. Picking the right one per employee — not per workforce, per employee — can be the difference between a clean filing and a 4980H(b) assessment. Our team runs the math on all three safe harbors for every employee and selects the one that produces the highest pass rate. The output is a defensible affordability methodology you can document to the IRS.
Controlled Group / Aggregated Employer Testing
Section 414 analysis and aggregated ALE determination for organizations with multiple EINs.
Most ACA penalty assessments on multi-entity employers trace back to a controlled group classification error. Section 414(b), 414(c), 414(m), and 414(o) define when separate legal entities must be treated as a single employer for ACA purposes — and the IRS calculates your 50-employee threshold, your 95% offer requirement, and your 1094-C aggregate section on that combined basis whether you classified it that way or not. Our team does the controlled group analysis explicitly, documents it, and structures the filings accordingly.
ALE Testing
Applicable Large Employer determination with full-time and FTE math.
ALE status is the gate that determines whether you have to file at all. The math is straightforward in theory — 50 full-time-equivalent employees during the prior calendar year — and full of edge cases in practice. Seasonal employees, mid-year acquisitions, controlled group aggregation, and FTE conversion rules all affect the number. Get it wrong, and you’ve either over-filed or missed a year. We compute the determination correctly and document the methodology for IRS defensibility.
Measurement Period Analysis
Look-back versus monthly methodology and period structuring.
The Look-Back Measurement Method is one of the most powerful tools the ACA gives employers, and one of the most consistently misused. Choosing the wrong measurement, stability, or administrative period — or applying the wrong method to variable-hour employees — invalidates the protection it provides. Our team analyzes your workforce, recommends the methodology that fits, structures the periods correctly, and documents the choice for the rest of the engagement.
Retrospective Analysis & Historical Exposure Modeling
Looking back at past plan years to surface what the IRS would have flagged.
The IRS has up to three years to assess penalties on a given plan year. Most employers don’t know what their past filings actually look like through the IRS’s eyes. Retrospective analysis reconstructs past plan years from the data you still have, runs the compliance math we run on current returns, and quantifies the exposure you’re carrying from filings you’ve already submitted. Where the analysis surfaces correctable issues, we can file corrections. Where it surfaces structural problems, we have time to prepare a defense.
Or start with the questionnaire.
A Penalty Exposure Assessment is the most direct way to see where your ACA risk actually sits. Eighteen questions, about three minutes, reviewed by a practitioner before any call. If you’d rather get a read on your exposure before scheduling a conversation, that’s the right starting point.
You might also need:
ACA Filing →
Strategy without execution is half the work.
IRS Penalty Defense →
If retrospective analysis surfaces something the IRS already noticed, defense is the next step.
Fully Managed ACA Compliance →
Advisory plus filing plus defense, under one engagement, year-round.