ACA Software Security Questionnaire for Benefits Data

List the information the employer intends to provide: employee identity, employer context, offer facts, contributions and covered-person enrollment where applicable. The 2025 C-series instructions help identify the reporting fields, but the purchased service may also receive import files, support attachments and historical exports beyond the final form.

Draw the actual path from source export to upload, application review, transmission service, recipient handling and retained records. Identify other providers involved. Ask which parts are operated directly by the vendor and which depend on another service.

NIST SP 1300 emphasizes inventorying and classifying data and assessing supplier risks. Begin the questionnaire with that scope so the security reviewer can judge relevant evidence. A general corporate policy may not describe the particular application or support process being purchased.

Add response date, applicable service, evidence period, limitations and unresolved questions to each row. Keep sensitive vendor evidence in the authorized review location.

Ask whether authentication controls apply to administrators, ordinary users, support personnel and integrations. Record which protections the vendor enforces and which the customer must configure. A capability that is available but disabled in the purchased setup is a different result from an enforced control.

NIST's guide recommends restricting sensitive access to those who need it and using multifactor authentication where available. Turn those principles into a scoped demonstration: an authorized test user can inspect the intended employer, while a restricted user cannot perform a disallowed action through the normal workflow.

Ask how access is removed when a person changes roles or leaves. Include exported files and support attachments in the discussion, since removing application access does not necessarily remove copies already downloaded to another approved location. Assign the employer's part of that process explicitly.

Fictional example: a vendor response says uploaded source files are removed from active storage 30 days after account closure, while backup copies age out after 90 days. The employer's reviewer initially records data deleted after 30 days. That summary omits a 60-day difference between the two stated periods.

The reviewer asks which data categories each statement covers, what access remains possible during backup retention, how a restoration affects deletion, and what evidence of completed removal is available. They also ask whether generated forms and support attachments follow either period or a separate schedule.

The outcome is a clarified data-lifecycle record, not a declaration that either period is inherently compliant or noncompliant. The employer's records and legal reviewers assess the agreed terms against applicable requirements. Before closure, operations separately verifies that necessary historical evidence has been exported and can be retrieved.

When a vendor offers an independent report or assessment, ask the reviewer to confirm the service scope, period covered, exceptions and customer responsibilities. A document covering a different product or an earlier operating model may need additional evidence. Record what was reviewed and what it actually supports.

Distinguish a policy, a contractual commitment, a configuration screenshot and a completed test record. They answer different questions. A recovery policy describes intended practice; relevant test evidence helps assess whether that practice was exercised. Do not mark a test completed merely because a plan exists.

Route legal applicability questions to the employer's qualified reviewer. Do not assume that a familiar acronym applies identically to every benefits reporting service. The questionnaire's job is to collect scoped evidence and identify responsibilities, not to invent a blanket compliance conclusion.

Summarize accepted evidence, unresolved items and required customer settings. For each condition, identify who will configure or verify it and when the implementation can rely on it. If the employer accepts a limitation, record the decision and operating procedure through its normal review process.

Connect the results to the implementation plan. Authentication setup, access scopes, approved upload methods and historical exports should become actual tasks. Preserve the vendor's relevant responses and the employer's review decisions together.

Keep a clear contact path for security questions and service incidents after launch. Revisit the affected questionnaire items when the service boundary, data types or vendor arrangements change. A completed procurement questionnaire describes a reviewed point in time; it does not remove the need to manage later changes.