Toast Payroll: Utilize ACA Reporting

This article only applies to customers who are using Toast Payroll's Classic Benefits module. This does not apply to SimplyInsured customers through Toast Payroll Pro or customers who use the deductions-only method.

In this Article:

Access ACA Reporting
Determine Applicable Large Employer (ALE) Status
Look-Back Measurement Tracking and Eligibility
Put ACA Reports Into Action
ACA Filings
Filing Documents

Access ACA Reporting in the Classic Benefits Module

Toast Payroll ACA (Affordable Care Act) reports are available to HR+ users with the Classic Benefits module by navigating to Benefits > View and manage health benefits > ACA Reporting. This tab should be used year-round.

Reports on this page will pull based on your specific measurement rules and hours data. If you have not been running payroll with Toast for longer than your ACA look-back period, hours may need to be imported for your company. If you are unsure of your look-back period, please contact benefitsops@toasttab.com.

Determine Applicable Large Employer (ALE) Status

Toast Payroll does not automatically file multiple FEINs as an Aggregate ALE Group if they do not exist under the same company code. Likewise, Toast Payroll does not automatically file multiple company codes as an Aggregate ALE Group.

If you have FEINs across multiple company codes that should be filed together as an Aggregate ALE Group, please reach out to benefitsops@toasttab.com to request this specification for your filing.

Before beginning the ACA filing process, employers should determine if they are an Applicable Large Employer (ALE.) The IRS recommends reviewing ALE status throughout the year to ensure compliance with any ACA reporting requirements. An ALE may be subject to applicable provisions under the Affordable Care Act, including requirements to submit certain year-end documents, such as Form 1095-C, to the IRS.

The IRS defines an ALE as an employer who has at least 50 full-time employees, including full-time equivalent employees, on average during the prior year.

Note: The most up-to-date version of Toast Payroll’s Determining Large Employer Status report is only available to customers who have been running payroll through Toast since the beginning of the previous calendar year. For example, if you want to run this report in July 2025, you will need to have been running payroll through Toast since January 1, 2024. If you have not run payroll through Toast since the beginning of the previous calendar year, please follow this link for further information.

To access Toast Payroll’s Determining Large Employer Status report, follow these instructions:

Navigate to Benefits > View and manage health benefits > ACA Reporting.
In the top box, select the following from the drop-down menus:
1. Customer FEIN: Select All FEINs. Our report does allow you to break down your data by FEIN, but Large Employer status is based on company common ownership, not by FEIN.
2. Lookback Year: Select the calendar year prior to the year you’re looking to determine if the employer healthcare mandate applies to your company, requiring you to file for that year. For example, if you are determining if you have to file in 2025, you would select 2024.
3. Lookback Ending Month: Select December.
4. Number of Months: Select 12.
Once all fields are populated, select Analyze Large Employer Status. The system will generate a yes/no answer to "Are you an Applicable Large Employer (ALE)?"
1. Note: Toast Payroll system automatically generates this analysis based on the data you have provided and as a helpful tool to assist you in making the determination as to whether you are an ALE. This tool is not intended to provide professional conclusive advice or guidance regarding your ALE status.
Select Audit by Employee to see the breakdown of employees who qualify as full-time or full-time equivalent. This will calculate the number of employees who have worked over 120 hours in the look-back period.
Select Audit by Earning to see which hours and how many are included in the average.
Reports can be exported to a spreadsheet by checking the Export to CSV box and selecting one of the 3 Analyze/Audit buttons.

Look-Back Measurement Tracking and Coverage Eligibility Determination

If you have determined that your company is an ALE, the Look-back Measurement Tracking and Coverage Eligibility Determination tools may assist you as you review measurement data.

Keep in mind that employee information will automatically generate individual measurement dates based on their hire date listed in Toast Payroll. The following reports may assist by systematically calculating if an employee may qualify as a full-time or full-time equivalent employee.

There are 3 report types to choose from:

Summary: This will provide a quick count of total employees, total full-time employees, and the employees offered coverage. Used for general numbers and budgeting.
Detail: This will return data will full details including Benefit Tier, Hours Worked, etc. Used to support the summary reports as needed.
Alerts: This will return employees that the system calculates as requiring an offer of medical coverage.

Within the reports, there are also additional subcategories to choose from:

Ongoing: This report will show employees that have completed a full measurement period and are now eligible for medical coverage based on the hours worked in that period.
Initial: This report will show new hires that have completed their measurement period and are eligible for medical coverage based on the hours worked in that period. These employees are now within their administrative period.
Pace: Not required, but this is a useful report to see who you may need to offer coverage to within the employee’s next administrative period. This report is only based on the complete months worked. Measurement periods for new hires will begin on the first of the month after their hire date.

Select Report Type based on the descriptions above. Select View to see the results on-screen or Export to download the data to excel.

Review this chart for a few examples of the most commonly used ACA reports:

Report Type	What does this report do?	What employees will appear in this report?	What is the measurement start date on this report?	Example
Initial Alerts	Alerts employers of employees who have become eligible for an offer of coverage following their measurement period	New hires that have completed their measurement period and worked an average of 130+ hours per month	The employee's date of hire or first of the month following date of hire (this is specific to your module setup)	An employee is hired on 2/1/24 and completed their 12 month measurement period on 1/31/25. On 2/1/25, the employee shows up on the Initial Alerts report because they worked 130+ hours per month on average over the 12 month period. This lets the employer know this employee is now eligible for an offer of coverage.
Ongoing Detail	Provides employers with an overview of employees who completed the company's most recent measurement period	Employees who were hired before the start of the company's most recent measurement period (e.g. if the measurement start date is 1/1/25, employees hired on 12/31/24 or earlier will show on this report	The first day of the company's most recent full measurement period	An employer with a 12 month measurement period has a measurement start date of January 1. The Ongoing Detail report is run on 1/1/25 and shows all employees who worked the full 12 month measurement period running 1/1/24 - 12/31/24. When this report is run again in 2026, it will show the 1/1/25 - 12/31/25 period.
Pace Detail	Provides employers with a "birds-eye view" of all employees currently being measured	New hires and ongoing employees	Varies; will show each employee's most recent measurement start date	An employee with a 12 month measurement period is hired on January 1. The Pace Detail report is run at any point during those 12 months so the employer can check whether the employee is "on pace" to become eligible once their measurement period ends.

Put ACA Reports Into Action

Use the results of these reports to assess how employees should be offered medical coverage and enrolled based on their elections.

If you use Toast Payroll’s Classic Benefits module, you can update the employee's benefit tier by navigating to Benefits > View and manage health benefits > ACA Reporting and scroll down to locate the Look-back Measurement Tracking and Coverage Eligibility section.

Choose the FEIN and ACA Tier you'd like to view.
Under Report Type, select the Alerts report you wish to run.
Select View to see the results on the screen.
Select Offer Coverage to the left of the employee. To offer coverage to all eligible employees, select Offer Coverage to All EE's (employees).
From the pop-up, select the applicable Benefit Tier.

The system will then provide access to employees to enroll in benefits. If your company is in Open Enrollment, the employee can follow the same enrollment process as the rest of the company. For those enrolling in a mid-plan year, the Toast system will provide benefit access for a Qualifying Event. See more about enrolling in benefits through Toast Payroll here.

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ACA Filings

Navigate to Benefits > View and manage health benefits > ACA Reporting and scroll down to locate the ACA Filings section. Review your filing data by selecting the FEIN you wish to view (or All FEINs) and the Year and select the following:

Review Filing Data: Review the coding for all employees for the year selected. See more of how to utilize this report in the “Step 3: Audit” section of our Filing Guide.
Export Monthly Data: This report breaks down each employee's hours and 1095-C codes by month. Use this to audit those codes against that hour's data.
Export Filing Data: This report has the same data as the Review Filing Data.
Import Filing Data: This allows you to update any fields on the “Review Filing Data” and import the updates back into the system. Take care to select the correct year and information as this will impact what appears on the employee 1095-Cs. Note imports can only be done for completed calendar years.

Filing Documents

To access all 1094-C’s that Toast Payroll has filed on your behalf, navigate to Benefits > View and manage health benefits > ACA Reporting, scroll to the Filing Documents section, and select the blue link in the Name box.

This content is for informational purposes and is not intended as legal, tax, HR, or any other professional advice. Please contact an attorney or other professional for advice.