Hi,
I know that we must count our interns and fellows in terms of determing large employer status. What's unclear to me is whether we are required under PPACA to offer them coverage. Interns typically work 3 months but that may be extended in some cases. Fellows typically work 6 months. Both types of employees work 40 hours per week while on board. Currently, they are considered ineligible for our benefits.
May we continue to exclude them under PPACA? If we do continue to exclude them and they receive a subsidy on the exchange, are we liable for the 3k penalty? Or, does the penalty not apply since they were not eligible for our plans to begin with?
Thanks!