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Tips for Managing Affordable Care Act Compliance in K-12 Schools

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The Affordable Care Act (ACA) has been on the books for over a decade. Still, its longevity hasn’t necessarily made it any easier for organizations to stay in compliance. ACA compliance can be especially challenging for K-12 schools, who must also manage compliance with Title 1 requirements and a slew of other employment laws.

ACA compliance is also difficult for K-12 schools because of the broad range of work schedules and job types within a district, including teachers, administrators, custodians, bus drivers and substitutes. However, achieving full compliance is not unattainable, nor does it have to be a time-intensive burden. In using workforce management technology to simplify time tracking and leave management, you can determine which employees are eligible for benefits per ACA requirements.

About the ACA: Compliance Challenges Facing K-12 Schools


The ACA regards any employer with 50 or more employees as an applicable large employer (ALE). As an ALE, your school district must provide affordable health insurance to at least 95 percent of its full-time employees. To determine eligibility, the IRS defines a full-time employee as anyone working at least 30 hours per week. However, because K-12 schools have varying operating hours throughout the calendar year and annualized employees who work different schedules, determining employee eligibility isn’t as straightforward as it might be for other employers.

A key ACA compliance challenge facing K-12 schools is tracking hours, as employees may split their time between facilities or work in different roles throughout the year. For example, an employee who works at the front desk in one school may also serve as a part-time bus driver in the district. Or teacher’s aides who work part-time during the school year may work full-time hours during the summer, providing enrichment support for Title 1 activities.

Despite the challenges, your school district must still comply with the ACA to avoid non-compliance penalties, which can be steep. As the Society for Human Resource Management (SHRM) illustrates, if an employer with 150 employees doesn’t offer health insurance to all eligible full-time employees, and has at least one employee using coverage through a government exchange, they could be liable for a $330,000 penalty. One school district reportedly racked up an $8 million penalty for such a violation.

Tips for Managing ACA Compliance


When you have the right processes and systems to track employee hours and benefits eligibility, you can overcome compliance challenges and meet Affordable Care Act requirements with ease.

Take the following steps to boost ACA compliance in your K-12 district:

Use a comprehensive time and attendance tracking solution.
Given the many annualized positions in your school district, the variability of employee schedules and number of support staff who wear many hats, you need a time and attendance solution that helps you calculate employee working hours throughout the year.

To comply with the ACA, it’s not just a matter of summarizing working hours for the year. You also need to select one of two calculation methods to determine if employees meet the IRS definition of a full-time employee. Using a fully customizable time and attendance system, you can make calculations using either of the following methods:


Know what information you need for annual ACA reporting.
As an ALE, your school district must complete and file IRS Form 1094-C, which details the benefits coverage you offer full-time employees every year. To complete the form, you will need to have the following information handy:

  • A total district headcount.
  • A record of all employee working hours and absences.
  • A list of employee benefits eligibility dates.
  • The share of the healthcare insurance premium employees pay.

Utilize tools for digital recordkeeping.
Gathering all the information you need for annual ACA reporting is much harder if you have to search for paper timesheets and benefits enrollment forms. Instead, utilize an integrated document management solution to keep track of employee records, including time and attendance reports, employee classifications, and benefits enrollment data.

Be prepared for a potential audit.
At any time, your K-12 school district could be subject to an external audit conducted by the Department of Labor, the IRS, or another government body. As a result, you will need to identify and address any potential compliance gaps within your district before they are flagged in an audit. To stay prepared, regularly monitor changes in ACA requirements and conduct periodic self-audits to confirm you’re still in compliance.

Boost Your Compliance with the Affordable Care Act


Keeping your K-12 workforce management practices in compliance with applicable employment laws is no small feat. But it’s easier when you understand the requirements and have the resources to stay in compliance and manage potential employee management risks. To elevate your compliance with the Affordable Care Act and many other labor laws, read our free guide, Get Audit Ready: Handle Your K-12 Audit with Confidence.
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