ACA Reporting Advisor

Welcome to MSEC’s weekly ACA FAQ on reporting. While details on how to complete IRS forms 1094 and 1095 (such as what codes to use on specific lines of the form) will not be covered, general questions on reporting requirements will be answered. For detailed information on form completion, contact your tax advisor, payroll company, or insurance carrier. If you have a general ACA reporting question, email it to The most commonly asked questions will be answered in this forum. In addition, the Health Care Reform Learning Zone, found on the MSEC website (, is a rich source of information about the Affordable Care Act (ACA).

On Form 1094-C, what’s the difference between the employee counts in Part III for columns (b) and (c)?

Column (b)

Report the total count of full-time* employees only for that month, except do not include any full-time employees in a limited non-assessment period in the number. Include any employee who terminated or retired only for the months in which actively employed as a full-time employee. Remember the number of full-time employees must be aggregated across all reporting divisions and reported in this column if you are completing the authoritative 1094-C transmittal for your organization.

Column (c)

Include all employees in the count, whether eligible for health care coverage or not—full time, part time, employees in a limited non-assessment period, and seasonal employees. Those in certain ownership positions may not be included. Do not include a former employee for months after the employment relationship ends.

You may choose from five counting options to determine the number for column (c):

1)  first day of each month;

2) last day of each month;

3) the 12th day of each month;

4) the first day of the first payroll period that starts during each month; or

5) the last day of the first payroll period that starts during each month (so long as, for each month, the last day falls within the same calendar month as the first day of the payroll period).

The chosen date must be used consistently for all months of the year.

*See definition of full-time employees in the IRS Form 1094-C Instructions (page 13) here.