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ACA Reporting for Union Employees
Schneider DownsLink to more items from this source
[Guidance Overview]
Nov. 13, 2015

"First, it is important to understand that union employees are included in the calculation of the total number of full-time equivalent employees (FTEEs) for ALEs and Aggregate ALE Groups. Therefore, an employer with ten non-union full-time employees and forty union full-time employees would have a total of fifty FTEEs and qualify as an ALE subject to the reporting requirements under the ACA. It is ultimately the employer's responsibility to file Forms 1094-C and 1095-C, even when an employee participates in a multiemployer plan, such as a union plan. However, an employer may work with and seek assistance from the union in order to compile the necessary information and complete the forms."

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