Best Practices in Employee Time and Attendance


December 2016

ACA subsidy notice graphics

How to Handle an ACA Subsidy Notice

Appealing the notice could save you from an IRS investigation

This summer, some businesses started receiving notices that employees were qualifying for subsidized coverage through the Health Insurance Marketplace.  

Known as subsidy notices, they were sent by the Department of Health and Human Services to employers if employees qualified for premium subsidized health insurance.    

The purpose wasn't to point fingers at employers for doing something wrong. But they do notify employers that there may be an issue to investigate.  

3 Reasons Employees Receive Insurance Subsidies

There are three ways employees can receive insurance subsidies:

  1. The employee didn't have an offer of coverage from the employer
  2. The employer offered coverage, but it wasn't "affordable" or didn't provide "minimum value"
  3. The employee was in a waiting period and couldn't enroll for coverage         

Subsidy notices give employers a chance to investigate why the employee might have qualified for a subsidy. But more importantly, it gives employers a chance to appeal it. 

Receiving a subsidy notice does not mean an employer will automatically face Affordable Care Act (ACA) penalties at year's end. But all unappealed notices (or lost appeals) are turned over to the IRS for penalty investigations. 

So, it's important for employers to appeal any subsidy notices they feel are in error. 

Also, employees who receive subsidies by mistake or misunderstanding must repay that subsidy to the IRS. So, the sooner the employer appeals the better since the error will be caught and fixed, saving the employee money.

For more information on systemizing ACA subsidy notices, download the free white paper, To Appeal or Not to Appeal: 7 Steps to Systematize ACA Subsidy Notices, by Attendance on Demand.


Ask an Expert

Double-punching or missed punching is a problem at our facility. Is there a way Attendance on Demand can help?

Yes! ESS Mobile, Attendance on Demand's employee self-service app, notifies employees of missed punches or time card exceptions so employees can review and correct them immediately. It also gives employees the ability to approve their time cards and request leave. Learn more about ESS Mobile

Have a question about time tracking and scheduling? Ask our experts!


In the News

Timely news in HR and payroll from around the web

Judge blocks December 1st overtime rule but employers still need to track employee time

District court says Bridgestone Tire should not have deducted overtime shifts from employee's FMLA leave
Source: Society for Human Resource Management

Proposed bill in California could make farmworkers eligible for overtime after 40 hours of work instead of 60
Source: National Public Radio

Experts wonder if new overtime rules will reduce work for employees instead of increasing overtime pay
Source: Inside Counsel