When should I use line 23 instead of lines 24-35 on the 1094-C?

Line 23 of the 1094-C can only be used if the number/entry did not fluctuate throughout the year. If the minimum essential coverage percentage, full-time employee count, total employee count, ALE status or 4980H Transition Relief indicator changed during the year, lines 24 through 35 will be used instead of line 23.

ABC Company had 75 employees in January through May, but due to terminations had 70 employees in June through the end of the year. Since the number of total employees changed throughout the year, lines 24 through 35 will be used for column c, “Total Employee Count”.

XYZ Company had 60 employees every month of the calendar year. Since the employee count is the same for each month, line 23 can be used instead of lines 24 through 35.

Note: Using lines 24 through 35 for one column does not require other columns in Part III of the 1094-C to use lines 24 through 35. Example: Line 23 can be used for column a (“Minimum Essential Coverage Offer Indicator”) while column b (“Section 4980H Full-Time Employee Count for ALE Member”) uses lines 24 through 35. 

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