Finding Employee Eligibility

A lot of being compliant with the Affordable Care Act (ACA) has to do with offering the right amount of coverage to the right employees.

We’ve talked in depth before about minimum essential coverage, minimum value, employer responsibilities, and even employee affordability and dependent coverage, all of which help determine that the coverage you offer is the right amount. Today we’re going to focus on the latter part of ACA compliance: the right employees.

According to the Employer Shared Responsibility Provisions, applicable large employers (ALEs) must offer coverage to all of their full-time employees.

So how do you figure out your full-time employees? Count their hours! But keep in mind that the IRS considers 30+ hours/week (or 130+ hours/month) to be full-time.

The hours you’re totaling should include:

• The employee’s hours worked
• Paid Family and Medical Leave of Absence (FMLA)
• Vacation days
• Sick days
• Jury duty
• Military duty

The employee’s hours of service when totaling who is full-time in the eyes of the IRS should not include:

• Volunteer hours
• Work-study hours (performed by students, interns)
• Hours paid with foreign-source income

Total up these hours one of three ways:

• By calculating the actual hours of service each month for each employee
• By totaling the number of days each month the employee did eight (8) hours of work
• By totaling the number of weeks each month the employee did 40 hours of work

Whichever way you choose, you have to stick with it for the entire calendar year. You can switch it up again though once the year is up.


Once you’ve determined those hours of service, it’s time to offer coverage and file those ACA Forms 1094 and 1095. ExpressACAForms can help you with all that and more! Create an account today or give our customer support team a call to answer any other questions you have.