1094-C Monthly Counts: Build a Reconciliation Worksheet

Column (b) reports the applicable Section 4980H full-time employee count, excluding employees in a limited non-assessment period. The instructions use the employer's applicable monthly or look-back measurement treatment. Column (c) reports total employees using one of the permitted consistent monthly counting dates. See the 2025 column (b) and (c) instructions.

Document each method separately. An HR field labeled “full-time” may describe a benefits or scheduling category rather than the required ACA determination. Likewise, a list of everyone paid during the month is not automatically a permitted point-in-time total.

Do not assume the difference between the two columns is a reliable count of part-time employees. Their measurement rules differ, so subtraction can mix unlike populations.

The 2025 instructions permit specified approaches for column (c), including the first day, last day, or twelfth day of each month and specified payroll-period dates. The selected approach must be used consistently for the year. Review the complete permitted choices before adopting one.

Put the chosen approach in the workbook header and calculate the actual comparison date for each month. If a payroll-period method is used, retain the relevant period calendar and confirm that the selected date satisfies the instruction's conditions.

Ask payroll for the population on that date, not merely the latest export. Preserve hires, terminations, and rehires needed to reconstruct the historical snapshot. A report generated today can be useful only if it accurately reproduces the selected past date.

Fictional Stone Willow Services uses the last day of each month for its total employee count. Its reviewed full-time counts are calculated separately under its applicable method. All figures below are fictional and already reflect the relevant reviews.

For June, the reviewer starts with 94 people meeting the relevant full-time test before excluding seven in a reviewed limited non-assessment period: 94 - 7 = 87. Separately, the June 30 employment snapshot contains 109 total employees. The figures answer different questions.

Keep the person-level list behind each monthly count in controlled storage. Record the source version, count method, exclusions or adjustments, and reviewer. The summary sheet can contain counts and references without exposing the full employee population.

Explain month-to-month changes with event records. A jump after an acquisition or system conversion deserves particular attention. Confirm that the new source did not omit inactive historical employees or accidentally include another legal employer.

Compare the prepared form with the reviewed worksheet. The 2025 Form 1094-C shows separate monthly columns and an all-year row. An unchanged all-year entry should not survive when the supported monthly count actually varies.

Do not use the annual number of Forms 1095-C as the monthly employee count. Turnover and reporting scope can make those figures differ. Also do not add twelve monthly counts and treat the sum as a unique annual workforce without deduplicating and defining a separate purpose.

The 98% Offer Method has a specific exception from completing column (b). Confirm actual eligibility and use of that method before leaving the column blank; the exception does not remove the need to review other applicable fields.

Keep offer-indicator analysis separate from the count worksheet. Column (a) has its own instructions and considerations. A reconciled headcount alone does not establish the employer's correct offer-indicator selection.

Have the reviewer confirm the method header, monthly source populations, adjustments, and prepared values. Record any unresolved question with its affected month. If the counting method or source logic changes, rerun the relevant year consistently and review the differences.

Retain the supporting lists and calculation references with the employer summary. A later question about June should be answerable from the June source and method, not from a current payroll screenshot.

The downloadable worksheet provides twelve rows and separate columns for each count's evidence. Populate those references before approval. That small discipline makes the monthly numbers reproducible and helps prevent a familiar operational headcount from being used in the wrong field.