What is a first-time Applicable Large Employer(ALE)?

There is a limited non-assessment period for first-time Applicable Large Employers (ALEs), which means that during this period an ALE Member will not be subject to a penalty for failing to offer coverage to a full-time employee. This period is January through March of the first calendar year in which an employer is an ALE, but only for an employee who was not offered health coverage by the employer at any point during the prior calendar year.

For example, if 2019 was the first calendar year in which a company was an ALE, then their limited non-assessment period is January through the end of March 2019. During this three-month period, this first-time ALE will not be penalized for failing to offer coverage to an eligible employee, but only if that employee was not offered health coverage by the employer at any point during 2019.

In addition, January through the end of March 2019 only counts as a limited non-assessment period if the employer offers the employee minimum value health coverage by the first day of the first month following the end of the period.

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