Should I Report My Full-Time Interns on Form 1095-C?

Lyndsey R. Barnett  

We previously wrote about offering coverage to interns, and now as the January 31st Form 1094/1095 deadline rapidly approaches, clients have started asking a logical follow-up question:  ok, so I have to offer coverage if they work full-time and satisfy our waiting period, but do I have to report them as a full-time employee?   

It depends. If the intern does not complete your plan’s waiting period, you would not have to report them because an individual is not considered a “full-time employee” when in a limited non-assessment period (which is a fancy term for a waiting period that is 90 days or less). If the intern works past the waiting period, you will need to report the intern if the intern was working a full-time schedule. If the intern does not receive an offer of coverage, you have to report it as such and risk incurring a penalty under the ACA if the intern receives a subsidy from an Exchange plan during that month. For any intern you have to report, you indicate in Line 14 that they were in a “limited non-assessment period” (Code 2D) for the entire time the intern was in the waiting period. 
The ACA has certainly made managing interns messier than usual. Reporting them inaccurately (or not reporting them at all) can have significant consequences, so if you have any questions when you are preparing your returns for the IRS, please give us a call.