For many organizations, ACA reporting becomes a once-a-year task that is handed off to a payroll provider with the assumption that everything is being handled correctly. While payroll and benefits vendors are valuable partners in the reporting process, one of the biggest misconceptions employers make is believing that outsourcing the administrative work also transfers the compliance responsibility.
It doesn’t.
At the end of the day, the employer remains responsible for the accuracy of the information submitted to the IRS. That’s why ACA reporting should never be viewed as a “set it and forget it” process. It requires active oversight from HR, payroll, benefits administrators, and leadership teams to ensure the information being reported is accurate, complete, and defensible.
While the forms themselves may seem straightforward, the data behind them often isn’t. Employee classifications, eligibility tracking, measurement periods, affordability calculations, enrollment elections, and employment status changes all impact reporting accuracy. A small error in any of these areas can create unnecessary compliance concerns, IRS notices, or significant time spent researching and correcting issues.
The Hidden Risk of Relying Solely on Your Payroll Vendor
Payroll providers have sophisticated systems and reporting capabilities, but those systems are only as accurate as the data they receive. Common reporting issues include employees being incorrectly classified as full-time or part-time; incorrect hire or termination dates; missing benefit eligibility information; coding errors on ACA forms; inaccurate employee contribution amounts; incomplete enrollment records; and data discrepancies between payroll and benefit systems.
When errors occur, many employers are surprised to learn that the IRS will hold the employer accountable, not the payroll vendor.
Technology is a tool. Compliance still requires human review.
HR must be involved in ACA reporting because payroll systems cannot fully interpret employee status changes, benefit waiting periods, variable-hour eligibility, leaves of absence, or coverage decisions. Before filing, HR should reconcile payroll, HRIS, benefits, enrollment, and personnel records to ensure the forms are accurate and complete.
Don’t Wait Until Filing Season
One of the most common mistakes employers make is waiting until January or February to begin reviewing their ACA data.
By that point, if problems are discovered, there may be limited time available to investigate and correct them before filing deadlines.
For reporting related to the 2026 calendar year, employers should already be thinking ahead to the electronic filing deadline in March 2027. Organizations that monitor and audit ACA-related data throughout the year are typically in a much stronger position than those that wait until filing season arrives.
ACA Reporting Checklist: Questions Every Employer Should Ask
Before submitting ACA forms, organizations should be able to confidently answer “yes” to the following questions:
✅ Have employee classifications been reviewed?
✅ Have all hire, termination, and status change dates been verified?
✅ Have payroll and benefits records been reconciled?
✅ Have employee contribution amounts been validated?
✅ Has HR reviewed the information being reported?
✅ Have all ACA reporting forms been reviewed before submission?
✅ Are copies of all filings being retained by the organization?
If the answer to any of these questions is “no,” it may be worth conducting a more thorough review before filing.
At Hanna Resource Group (HRG), we help organizations identify compliance gaps, review ACA reporting processes, validate employee eligibility tracking, and strengthen overall HR compliance practices.
Whether you need support with ACA reporting, a broader HR compliance review, or ongoing HR consulting services, our team can help ensure your processes are accurate, documented, and positioned for long-term success.
Contact us to learn more about how we can help!
Moving From Adoption to Accountability
Because AI adoption is already happening, organizations need to decide how intentionally they will manage it. HR has an important role because AI is changing more than technology. It is changing how people work, what skills employees need, how decisions are made, and how organizations manage risk.
But HR should not do this alone. IT brings technical expertise. HR brings the workforce perspective. Leadership provides direction and accountability. Together, these groups can help organizations capture the benefits of AI while creating clear expectations around responsible use.
The first step does not have to be complicated: Assess what is already happening. Establish clear expectations. Train employees. Create shared oversight. Continue evaluating and adapting. The goal is to create a framework that allows organizations to innovate while protecting their people, information, and business.
If your organization is evaluating AI adoption, developing an acceptable use policy, training employees, or determining how AI will affect recruiting and workforce management, Hanna Resource Group can help. Our team can partner with your organization to assess workforce risks, establish practical governance processes, and create strategies that support responsible innovation.
