Employee benefits compliance sits at the intersection of federal tax law (IRC), labor law (ERISA), and healthcare law (ACA). The three regimes each impose distinct requirements, different agencies enforce them (IRS, DOL, PBGC), and the penalties for non-compliance can be severe.

ACA Employer Mandate

The Affordable Care Act's employer shared responsibility provisions under 26 U.S.C. § 4980H apply to "applicable large employers" (ALEs) — employers with 50 or more full-time equivalent employees in the prior calendar year. ALEs must offer minimum essential coverage that is affordable and provides minimum value to full-time employees (30+ hours/week) and their dependents.

Penalty amounts (2025): Section 4980H(a) — $2,970 per full-time employee per year if the employer fails to offer coverage to at least 95% of full-time employees and any employee obtains a subsidized Exchange plan. Section 4980H(b) — $4,460 per full-time employee who obtains a subsidized Exchange plan if coverage offered is unaffordable (premium exceeds 9.02% of household income) or lacks minimum value.

ALEs must file Forms 1094-C and 1095-C with the IRS and furnish Form 1095-C to each full-time employee by January 31.

COBRA Continuation Coverage

COBRA under 26 U.S.C. § 4980B requires group health plans sponsored by employers with 20 or more employees to offer continuation coverage to qualified beneficiaries who lose coverage due to a qualifying event. Key timelines: Initial Notice within 90 days of enrollment; Election Notice within 14 days of receiving notice of a qualifying event; 60-day election period for beneficiaries; 18–36 months of coverage depending on the qualifying event.

Penalties for COBRA failures: $110/day per qualified beneficiary for notice failures under 29 U.S.C. § 1132(c)(1), plus potential IRS excise taxes.

ERISA Plan Documents

ERISA (29 U.S.C. Chapter 18) applies to virtually every employee benefit plan offered by a private employer. SMB requirements include: a written plan document for every ERISA-covered plan; a Summary Plan Description (SPD) provided to participants within 90 days of enrollment; Form 5500 annual filing for plans with 100+ participants; and PCORI fees (due July 31) for self-insured health plans.

How Compliance Singularity Handles Benefits Compliance

Compliance Singularity tracks your employee count against ACA ALE thresholds throughout the year and alerts you when approaching 50 FTEs. For ALEs, it calendars 1094-C/1095-C deadlines. COBRA notice obligations are triggered from your HRIS integration when qualifying events occur. Form 5500 filing deadlines are tracked per plan and filed automatically for qualifying plans.