Full-Time Employee Service Hours: How to Add Them Up

Yesterday, we gave you the basic formula for calculating your employees’ total hours worked so that you could assess how many full-time equivalent employees (FTEs) you employ. It’s important to know the exact number of FTEs working for you for the sake of filing your Affordable Care Act return. When totaling your employees’ hours worked, you’ll want to make sure you’re calculating them in one of the three IRS-allowed ways to ensure your ACA compliance.

Before we get down to the types of calculation, let’s clarify what’s included in hours of service. Obviously, it’s hours spent working by the employee, but hours of service also include hours for which the employee is paid for:

• vacation or holiday,
• illness or incapacity (including disability),
• layoff,
• jury duty, and
• military duty or leave of absence.

When calculating your total hours of service, do not include hours for seasonal employees (who work less than 120 days).

Actual Hours Worked
The most straight-forward method, the Actual Hours Worked calculation method determines the actual hours of service from records of hours your employees worked and were paid. So if your payroll records indicate an employee worked 2,000 hours and was paid for an additional 80 hours (for vacation, holiday, and illness leave), the employee would have worked 2,080 hours of service for the year.

Days-Worked Equivalency
If you use the Days-Worked Equivalency method, you’ll credit an employee with eight hours of service for each day the employee was required to work at least one hour of service, including hours of paid leave. In other words, if you use this method and you have an employee who works from 8:00 a.m. to 12:00 p.m. each day for 200 days, the employee would be credited with 1,600 hours of service (8 hours for each day worked, multiplied by 200 days).

Weeks-Worked Equivalency
This method is a little similar to our previous one, only it goes by weeks instead of days. When you use the Weeks-Worked Equivalency method, you credit an employee with 40 hours of service for each week for which payment is made or due (including weeks of paid leave). For example, if you have an employee who worked 49 weeks and took two weeks of vacation with pay, the employee must be credited with 2,040 hours of service (51 weeks x 40 hours/week).

E-filing With ExpressIRSForms
When you e-file with ExpressIRSForms, you have access to our full-time employee calculator, making your ACA e-filing that much easier. To get started, just create an account, then follow the steps to generate and e-file your forms. If you run into any problems or have a question, you can give our expert customer service team a call at (704) 684-4751 Monday through Friday, 9;00 a.m. to 6:00 p.m. ET or send us an email anytime to support@ExpressIRSForms.com.

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Minimum Value

Going hand-in-hand through the ACA regulations with Minimum Essential Coverage (MEC), which we posted about earlier this week, is Minimum Value (MV). 

What is Minimum Value?
Healthcare plans meet a Minimum Value (MV) if they’re designed to pay for at least 60% of the total cost of medical services for a standard population, according to the Affordable Care Act (ACA). This minimum standard is the equivalent of a Bronze plan sold on the Health Insurance Marketplace. The plan’s benefits must also include a substantial amount of any inpatient hospital and physician services necessary.

In order to remain completely compliant with the ACA, the healthcare plan you as an employer offer your employee(s) must offer both Minimum Essential Coverage and meet the Minimum Value allowed. If the plan you offer doesn’t meet MEC or MV standards, you might have to pay an employer shared responsibility payment.

An employer shared responsibility payment is incurred when their employee receives a premium tax credit when purchasing additional insurance from the Marketplace. Since the employee would only receive this tax credit if their existing insurance didn’t meet MEC or MV guidelines, this could launch an IRS investigation into your coverage offers and you could end up paying out of pocket for each full-time employee considered under-covered.

However, just because an employee seeks additional insurance from the Marketplace doesn’t mean he/she will automatically receive the premium tax credit. If the insurance you provide meets MEC and MV, the employee will still be able to purchase additional coverage but they won’t be eligible for the credit.

The clock is ticking to get your ACA forms e-filed! The deadline is June 30, so be sure to sign up with ExpressIRSForms to complete your ACA filing today. And if you have any questions, our customer support team is happy to help! Give us a call Monday through Friday, 9:00 a.m. to 6:00 p.m. EDT, at (704) 684-4751 or send us an email anytime at support@ExpressIRSForms.com.

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Reporting Safe Harbor & Affordability on Line 16 of Form 1095-C

A couple of slots down from Line 14 on Form 1095-C is Line 16, as is usually the case with sequential numbers. The thing about Line 16 is that not everyone will fill it out. Read on to learn more about this reporting requirement.

Form 1095-C, Line 16
The thing to keep in mind about Line 16 is that you’ll only fill it out if certain situations apply for the employee (i.e., the employee not being full-time or employed at all) or for you, as the employer (i.e., Safe Harbor relief eligibility), during any month of the year.

ACA Code Series 2
The following Safe Harbor Codes are used on Line 16 of Form 1095-C:

• 2A: Employee was not employed during this month.
• If the employee worked even one day that month, Code 2A is not applicable.
• Code 2A may not be used for the month an employee resigns.
• 2B: Employee is not a full-time employee.
• Use Code 2B for a non-FTE who didn’t enroll in coverage that month (if offered).
• Use Code 2B for FTEs whose coverage ended before the last day of the month because the employee resigned (otherwise, the coverage would’ve continued).
• Use Code 2B for January 2015 if you offered MEC with MV to the employee no later than the first day of the first payroll period beginning that month.
• 2C: Employee enrolled in coverage offered.
• Code 2C should be used even if another code might apply (other than 2E).
• Don’t use Code 2C if Code 1G is entered in the “All 12 Months” box on Line 14.
• Don’t use Code 2C for any month a terminated employee is enrolled in COBRA (use Code 2A instead).
• 2D: Employee in a section 4980H(b) Limited Non-Assessment Period
• Use Code 2D for any month the employee is in a Limited non-Assessment Period for section 4980H(b).
• If Code 2E is also applicable, use that instead of Code 2D.
• 2E: Multiemployer interim rule relief.
• Use Code 2E for any month the multiemployer arrangement interim guidance applies to the employee.
• Code 2E should be used regardless of any other code that may apply.
• 2F: Section 4980H affordability Form W-2 safe harbor.
• Use Code 2F for any month you used the section 4980H Form W-2 safe harbor to determine affordability for the employee’s coverage.
• 2G: Section 4980H affordability federal poverty line safe harbor.
• Use Code 2G for any month you used the section 4980H affordability federal poverty line safe harbor to determine affordability for coverage.
• 2H: Section 4980H affordability rate of pay safe harbor.
• Use Code 2H for any month you used the section 4980H affordability rate of pay safe harbor to determine affordability.
• 2I: Non-calendar year transition relief applies.
• Enter Code 2I if non-calendar year transition relief under section 4980H(b) applies to this employee for any month.

At ExpressIRSForms, we help make sure you have the right codes in the right places. With built-in error checks, we’ll make sure no obvious errors are sent in your forms to the IRS. And if you have any questions along the way, our support team will be happy to help! Give us a call Monday through Friday, 9:00 a.m. to 6:00 p.m. EDT, at (704) 684-4751. Filing in the middle of the night? We offer 24/7 assistance via email at support@ExpressIRSForms.com.



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ACA Compliance: How to Track Variable Hour Employees

Variable hour employees are those who, based on circumstances surrounding their employment, cannot easily be classified as a standard, 30-hour-per-week full-time employee. In other words, their schedules fluctuate so greatly, it requires a longer measurement period to determine whether they’re eligible for health coverage and benefits extended to other full-time employees.

But just because they’re variable hour employees doesn’t mean they can be swept under the rug. If any of these employees does work, on average, over 30 hours per week and you don’t make an offer of coverage to them, you could face a $100 per day penalty for each affected employee.

Employers are given a full year, or “measurement period,” under the ACA to determine whether or not their variable hour employees average 30+ hours of work each week. If an employee is discovered to have exceeded 30 hours/week, you must make an appropriate offer of coverage. It must go into effect within 90 days of acceptance and be available for a full 12 months, even if the employee’s hours worked drop below 30 hours/week. This time period that the employee is covered is called the “stabilization period.”

Unlike your regular full-time employees, variable hour employees must qualify for their offers of coverage each year by working that average of 30 hours a week. That’s why it’s recommended employers set their measurement period to start 90 days before the annual renewal date. So the measurement period for companies with a January 1 renewal date will measure their employees’ variable hours from October 1 to September 30 of the year before. This also makes it easier for handing out your offers of coverage, since you’ll only have one open enrollment period.

Already have your employees tracked and ready to file? Great! You can start with ExpressIRSForms today! And if you have any questions, don’t hesitate to call our customer support center in Rock Hill, South Carolina. We’re available Monday through Friday, 9:00 a.m. to 6:00 p.m. EDT, at (704) 684-4751 and 24/7 at support@ExpressIRSForms.com.



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Affordable Care Act Health Insurance & Compliance

When it comes to ACA compliant health insurance, a lot of new information is getting thrown around and things can get overwhelming pretty quickly. So here are a few key ACA terms to keep in mind when filing and staying compliant:

Self-Insured Coverage
For self-insured health plans - or self-funded, as they’re sometimes called - the employer assumes financial risk for providing health care benefits to employees. In other words, a self-insured employer would pay claims, usually from an earmarked fund, as they’re incurred instead of a fixed premium to an insurance carrier.

Fully Insured Coverage
Fully-insured health plans, which are the more traditional options for employers, have the employer paying a fixed premium to the insurance carrier each year based on the number of employees enrolled. In this case, the insurance carrier pays any health care claims based on the coverage terms.

Minimum Essential Coverage (MEC)
To put it plainly, MEC is the least amount of health care coverage you need to offer (and what you need to have, if you’re an individual reading this) your employees to remain ACA compliant. You can visit the IRS’s site here for more information on what types of coverage meet MEC requirements.

Minimum Value (MV)
Your employer-sponsored plan must provide the minimum value (MV) of coverage as dictated by the Affordable Care Act. The IRS states that a plan meets MV requirements if “it covers at least 60% of the total allowed cost of benefits that are expected to be incurred under the plan.”

Spouse & Dependent(s) Coverage
Under new Affordable Care Act regulations, offers of coverage to employees by ALEs must now include offers to the employee’s spouse and dependent(s), if applicable. Under ACA guidelines, a dependent is an employee’s child (including legally adopted children) who has not reached the age of 26.


Need to get started on your ACA e-filing? You can do so now at ExpressIRSForms! We’ve also created ExpressACAForms, a full-service e-filing option for Forms 1094 and 1095.

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Measurement Methods for Identifying Full-time Employees for ACA Purposes

One of the most important parts in ACA compliance is identifying which full-time employees to whom you’re required to make offers of health care coverage. First things first, however, you’ll need to determine if you’re an Applicable Large Employer (ALE). In other words, determine if you have 50 or more full-time employees. And keep in mind that the IRS considers 30+ hours a week (or 130 or more hours/month) to be full-time.

There are two methods for determining full-time employee status:

• The monthly measurement method
• The employer looks at each month the employee has worked individually to see which ones exceeded 130 hours of service
• The look-back measurement method
• The employee goes through a standard measurement period, where they work their usual hours as determined by the employee and employer upon hire.
• Then, the employer determines the employee’s full-time status based on the measurement period, during what is known as a stability period.
• Employers may not use the look-back method when determining ALE status, only for an individual employee’s full-time status.

When determining an employee’s status, an hour of service is considered to be each hour the employee is paid (or should be paid) for performing his/her duties as set by the employer, including the hours the employee is entitled to payment during which no duties are performed (like vacation pay, holiday pay, sick leave, disability, layoff period, jury duty, military duty, or leave of absence). For the purpose of the employer shared responsibility provisions, this does not include these hours of service/employees:

• Volunteer employees
• Students performing work-study
• Members of religious orders
• Compensation that isn’t US source income

You can find more information about totalling hours of employees in more nuanced categories, like adjunct faculty, those who work layover hours (like airline industry employees), and on-call employees, here.

If you have any questions regarding your ACA filing, you can give us a call at the ExpressIRSForms headquarters in Rock Hill, SC. We’re available by phone Monday-Friday, 9:00 a.m. to 6:00 p.m. EDT at (704) 684-4751, and we also offer 24/7 email assistance at support@ExpressIRSForms.com.




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Health Care Coverage: Self-Insured v. Fully-Insured

There are two main types of health plan employers need to consider when setting up the coverage they’ll over their employees: self-insured (or self-funded) and fully-insured.

The big difference between the two is in self-insured health care coverage plans, the employer assumes financial risk for the employees’ benefits, paying the claims out of pocket rather than a fixed premium to the insurance carrier, like fully-funded plan providers do. Read on to learn a little more about the more specific differences between the two plans.

Self-Insured Plans
Rather than purchasing a fully-insured plan from an insurance carrier, employers who choose a self-insured plan are opting to operate their own health plan. These employers are generally larger ones and benefit from this type of plan because it allows them to save on the premiums insurance companies charge for fully-funded plans. It can be risky, though, because the employer will end up paying more out of pocket if more claims than are expected need to be paid.

Fully-Insured Plans
A fully-insured health plan is the more traditional option for employers, especially if you’re on the smaller end of the ALE scale. For this type of plan, the employer agrees on a fixed premium each year, paid to the insurance company based on the amount of employees the employer has enrolled. The insurance carrier will then pay any health care claims throughout the year, and employees are responsible for any deductibles or co-pays required for services.

Now that you’ve got your ACA-compliant health care coverage, do you know how you’re filing your forms? ExpressIRSForms now offers e-filing for ACA Forms 1094 and 1095, or you can check out ExpressACAForms for our full-service e-filing option.

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