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Department of Human Resource Management
Office of State Health Benefits
December 17, 2025
Affordable Care Act (ACA) Reporting Update and Deadlines for Calendar Year 2025
Deadline 2: On-line ACA Certification Due by December 29, 2025
The annual ACA Certification is the final step in collecting information to file ACA reports for calendar year 2025. The online ACA Certification page is available in Cardinal and must be submitted by December 29, 2025.
Any primary group contact may submit the ACA Certification for their designated group number. Some employers have more than one group number. One certification is submitted under the primary employer group for all groups that share the same employer FEIN and reported to the IRS as one employer.
Please use the Cardinal ACA Data Entry page to certify the ACA data for your agency.
Navigation: Benefits > Employer Information > ACA Data Entry. The BN361 ACA Data Entry job aid includes detailed instructions.
The certification requires that you verify employer information and enter the number of employees for each month of 2025 using the ACA definitions published by IRS. The following information is required to submit the ACA Certification for calendar year 2025:
- Monthly counts of full-time employees for the employer FEIN, by ACA definition.
- Monthly counts of total employees for the employer FEIN, by ACA definition, regardless of full-time, part-time, or hourly status.
- Contact name and phone number for the primary employer FEIN.
ACA Certification counts are based on the ACA definitions published by IRS. You may use this link for IRS guidance: https://www.irs.gov/affordable-care-act/employers/determining-if-an-employer-is-an-applicable-large-employer.
The presentation and recording of the Cardinal HCM: 2025 ACA Process Forum for Agencies held on December 3, 2025 are available by clicking the buttons below.
A primary group contact may make corrections and re-submit the certification as needed prior to the deadline. The certification on file after the deadline is the certification that will be used for reporting to the IRS.
Things you can do to manage ACA information throughout the year:
- Be sure to collect an enrollment form from all new hires that are eligible for coverage – those that choose to waive coverage and those that choose to enroll. Be sure it includes the hire date and classification.
- Be sure to term records for employees that waived coverage when they are no longer eligible for coverage.
- Review reports to be sure enrollment information is accurate.
Thank you for your attention and assistance in this major ACA reporting requirement. Contact OHB for questions about the ACA reporting requirement.
- Office of Health Benefits (OHB)
- Email: ohb@dhrm.virginia.gov
- Fax: 804-371-0231
- Phone: 888-OHB-4414 (888-642-4414)
804-225-3642 in Richmond
Note: When you contact the Office of Health Benefits (OHB) about specific issues, be sure to include the employee’s name, the ID number, and a brief description of the issue. The Agency Request for Assistance Form is available on the DHRM website.
For technical or functional questions about reports or data entry in Cardinal, please submit a help desk ticket to vccc@vita.virginia.gov and include “Cardinal -" in the subject line with a brief summary for routing. In the email, provide detailed information about your issue (i.e., functional area, page, actions, error). Be sure to include your name, email address, and a phone number where you can be reached.
Please do no reply to this e-mail. You may send inquiries to the Office of Health Benefits mailbox at ohb@dhrm.virginia.gov.
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