Sequoia Tech / ACA Track - 2025 ACA Reporting Year Deadlines & Client Responsibilities

1. ACA Track / Client Implementation Meetings
   

1. Client Supplemental Data Due to ACA Track 
   

1. Client will be notified when ACA file is ready for review & ACA Track System Error Corrections  (Client responsibility)   

1. DEADLINE for the data file to be error free in ACA Track System and to generate 1095C forms for review (Client responsibility)
   

1. DEADLINE for 1095C forms to be approved and sent to print for ACA Track to file timely (Client responsibility)
   

1. DEADLINE for Headcounts entered and 1094C Forms Generated, Reviewed and Approved for submission to IRS (Client responsibility)
   

1. Schedule and attend implementation call with ACA Track – The purpose of this required meeting is to verify and approve company and plan information provided by Sequoia, review reporting year deadlines, and to establish if there is any supplemental data needed from the client.
2. Provide Supplemental Data (if applicable) – There are instances where the Client will be required to provide supplemental data files in addition to the data files that are provided by Sequoia. The scenarios that will require Client-provided supplemental data files will be discussed during the implementation meeting with ACA Track and are also indicated below in the “Supplemental Data Scenarios” section of this document.
3. Complete Error Corrections (if applicable)– Clients will be notified if there are any data discrepancies that need to be corrected.
4. November Employee Updates (if applicable) - Due to the new hire grace period for benefit election and constant changes of the workforce, it is suggested that Clients review the system file once uploaded to the ACA Track system to ensure that November new hires and terminations were captured.  Please make any necessary updates directly on the System file during the System Error Correction process.  
5. 1095 Form Review / Approval – Clients will review the batch detail report and generate the 1095 forms within the ACA Track System for review and approval. All forms must be approved by the deadline provided. 
6. Client Data Amendments – Amend data as needed following review of system file and/or 1095 forms. Any Client System File amendments will need to also be uploaded by the Client directly to the ACA Track System including any errors corrected prior to regenerating 1095 forms.
7. 1094 Form Review / Approval – 1094 forms will be generated by the Client within the ACA Track System for review and approval. All forms must be approved by the deadline indicated above. 
8. State Filing Submissions – If State Filing service was elected, your Reporting Specialist will contact you if additional steps are needed.
9. IRS Accepted with Error Responses – If the IRS provides a 1094C response of “Accepted with Error”, the Client is responsible for reviewing the report and uploading amended data within the ACA Track System as applicable for corrected form generation and submission to the IRS.
10. Storage of Annual Submissions – Client should download and save all approved 1095 PDF files and all 1094 PDF files that were submitted to the IRS for their records. It is the Clients' responsibility to ensure that these items are downloaded for client use and storage annually. 

1. must be in the template specified 
   

1. must contain the Client Name in the file name (ex: “ClientName_2025EINdata.xlsx”)
   

1. data must be submitted to ACA Track data portal no later than 12/4/2025; data submitted after this deadline will not be used in the consolidation and it will be the Client’s responsibility to add this supplemental data to the completed ACA Track System File

1. Multiple EINs – Clients who have employees in more than one EIN must provide a data file that contains Employee SSN, Employee Name, and Legal Entity Information (any indicator that identifies the legal entity that the employee works under); Note that this information should match the employee’s W-2 form for the 2025 tax year. 
2. State Reporting Identifier Lists – Clients who elect State Filing Services will have the option to provide a State Reporting Identifier data file that indicates the specific employees that need to be reported to each applicable state; or request to have ACA Track fill in state filing codes based on mailing address of file submitted by Sequoia.
3. December New Hires and Dependents (self-insured and level funded groups only) – Clients who have a self-insured or level funded medical plan will need to include December new hires to the data file if the employee is eligible for coverage during the current reporting year.  Clients can submit via a supplemental file or add the information to the ACA System file.
4. Address Updates – If a Client elects for ACA Track to use an address file that does not originate from Sequoia, then an address file may be provided to ACA Track that will override the addresses provided by Sequoia.