ACA Compliance During Mergers, Acquisitions, and Business Reorganizations
By involving HR, Payroll, Benefits, and benefits administration partners early in a corporate transaction can help avoid unnecessary ACA compliance issues.
Employers that maintain organized records, consistent procedures, and accurate data are better positioned to respond efficiently to audit requests.
An HR or benefits audit can come from a variety of sources, including an external auditor, insurance carrier, government agency, or internal compliance review. Regardless of who is conducting the audit, organizations that maintain organized records, consistent procedures, and accurate data are better positioned to respond efficiently and minimize compliance risks.
Rather than waiting until an audit is announced, employers should periodically review their HR and benefits administration processes to identify and address potential issues.
One of the first areas auditors often review is employee documentation. Personnel files should be complete, organized, and consistently maintained.
Consider reviewing records to ensure they include:
Remember that medical information, including FMLA certifications and accommodation records, should be maintained separately from personnel files.
Benefits records should accurately reflect employee elections and eligibility.
Review items such as:
Maintaining complete records makes it easier to respond to employee questions and demonstrate compliance if requested.
Consistent processes are just as important as complete records. Employers should periodically review written procedures to confirm they accurately reflect current practices.
Questions to consider include:
Documented procedures help promote consistency, especially when responsibilities are shared among multiple team members.
Many compliance issues result from inconsistent information between HR, payroll, and benefits records.
Periodically compare information such as:
Identifying discrepancies early can help prevent payroll corrections, employee issues, and reporting errors later in the year.
Access to HR and benefits systems should be reviewed regularly to help protect sensitive employee information.
Consider confirming that:
Regular access reviews support both security and good internal controls.
Many organizations require employees to complete annual compliance and security training. Before an audit, verify that required training has been completed and properly documented.
Common examples include:
Maintaining training records demonstrates your organization’s commitment to compliance.
An annual internal review can help identify gaps before they become audit findings. Consider using a simple checklist to confirm that employee files are complete, benefits records are current, payroll deductions are accurate, and written procedures remain up to date.
Preparing for an HR or benefits audit is not just about responding to requests. It is about maintaining organized records, accurate data, documented procedures, and strong internal controls throughout the year. By taking a proactive approach, employers can reduce compliance risks, improve operational efficiency, and be better prepared whenever an audit or compliance review occurs.
Benefit Allocation Systems (BAS) provides online solutions for: Employee Benefits Enrollment; COBRA; Flexible Spending Accounts (FSAs); Health Reimbursement Accounts (HRAs); Leave of Absence Premium Billing (LOA); Affordable Care Act Record Keeping, Compliance & IRS Reporting (ACA); Group Insurance Premium Billing; Property & Casualty Premium Billing; and Payroll Integration.
MyEnroll360 integrates with major insurance carriers for enrollment eligibility management (e.g., Blue Cross, Blue Shield, Aetna, United Health Care, Kaiser, CIGNA and others), and with leading payroll platforms for enrollment deduction management (e.g., Workday, ADP, Paylocity, PayCor, UKG, and others).
This article is for informational purposes only and is not intended as legal, tax, or benefits advice. Readers should not rely on this information for taking (or not taking) any action relating to employment, compliance, or benefits. Always consult with a qualified professional before making decisions based on this content.