Calculating Your ACA Business Size & Responsibility

NOTE for 2015: Employers performing this calculation may use any consecutive six month period to determine their ACA business size, unless they were planning on utilizing the seasonal worker exception. Seasonal businesses that wish to use the exception must use the entire 2014 calendar year for their calculation.

STEP 1 — Number of Full Time Employees

For each calendar month of the preceding calendar year, count the number of full-time employees (including seasonal employees) who work on average 30 hours per week per month. Employees that average 30 hours per week/per month are considered “full time employees” and count as 1 person each in the calculation. Total your number of full time employees for each month.

OPTIONAL: Separately note any seasonal workers that averaged 30 hours a week for each month in the white box below. “Seasonal workers” includes the following:

• Seasonal agricultural worker — defined as an individual who is employed in agricultural employment of a seasonal or other temporary nature. (NOTE: This would NOT include: migrant workers, immediate family members of agricultural employers, farm labor contractors OR H-2A workers).
• Retail workers employed exclusively through holiday seasons
• Employees that meet the following standard — 29 CFR 500.20(s)(1): “Labor is performed on a seasonal basis where, ordinarily, the employment pertains to or is of the kind exclusively performed at certain seasons or periods of the year and which, from its nature, may not be continuous or carried on throughout the year. A worker who moves from one seasonal activity to another…is employed on a seasonal basis even though may continue to be employed during a major portion of the year.”

STEP 2 — Number of Full Time Equivalent Employees

For each calendar month of the preceding calendar year, calculate the number of full-time equivalent employees by adding up the total number of hours worked by non-full-time employees (including seasonal employees).

Then divide that number by 120. These are your monthly “full time equivalents.” (For the monthly calculation, include fractions. For example, 800 hours / 120 = 6.7 FTEs.)

STEP 3 — Total Employees for ACA Calculation

For each calendar month of the preceding calendar year,
add the total from Step 1 and the total from Step 2 together.

STEP 4 — Initial ACA Business Size

Add each monthly total together and divide that number by 12.

Remove any fractions (numbers after the decimal point) for the annual calculation only.
(For example, an annual average of 49.9 FTEs would be considered 49 for the purposes of this calculation.)

The result of STEP 4 is your initial ACA business size.

• If the average does not exceed 50 full-time equivalents, by ACA standards you are considered
  a small employer. You do not need to do any further calculations.
  STOP HERE and go to the SAF Health Care Planning Tool for Small Employers.
• If the average is 50 or more full-time equivalents, GO TO STEP 5,
  to determine whether the seasonal employee exception* applies to your business

STEP 5 — ONLY if Your Initial Calculation is “LARGE EMPLOYER”

Review and examine your month-by-month full-time equivalent calculation totals.
Check off the box below your calculation for the months in which your
workforce exceeded 50 full-time equivalent employees.

STEP 6 — Recalculate Your Size

Remove eligible seasonal workers* from Step 1 (white box)
and all hours worked by seasonal workers from STEP 2 (white box)
and recalculate your business size.