Step 1: Calculate Full-time and FTE Employees
Use the FTE calculator in RUN Powered by ADP® (RUN) to determine your number of full-time and full-time equivalent (FTE) employees. In general, if you had a combined total of 50 or more full-time and FTE employees in the 2017 calendar year, you need to complete and file Forms 1095-C and 1094-C in 2019.
IMPORTANT: If you are part of a controlled group, you must combine all employees of each company when making this calculation.
Controlled groups exist when any two or more entities are treated as a single employer under section 414 (b), (c), (m), or (o) of the Internal Revenue Code. Where the combined total of full-time and FTE employees in a controlled group is 50 or more, each individual employer is subject to reporting with respect to its own common law employees (or prior employees).
Fewer than 50?
No action is needed, unless you are self-insured or have a level-funded plan. A self-insured plan generally means that the employer assumes the risk of paying participants' claims out of its general assets or a trust. A level-funded plan is a type of self-insured plan where rates are based on group experience. They typically have fixed monthly payments that are used to pay claims and maintain stop-loss coverage.
If you have fewer than 50 full-time and FTE employees and don't offer health coverage, you are not subject to these reporting requirements. If you have fewer than 50 full-time and FTE employees and offer a fully insured health plan, your insurer is responsible for filing the required forms with the IRS and furnishing the forms to your employees.
50 or more?
If you have 50 or more full-time and FTE employees, or you offer a self-insured (or a level-funded) health plan, proceed to Step 2.