Are you over the 50-employee threshold so that you are required to give health coverage or pay a penalty (starting in 2015 if 100+ employees or in 2016 if 50 to 99 employees)? According to Question 55 in the IRS’s Q-and-As on Employer Shared Responsibility Provisions, count interns’ hours as you would any employee. If they’re unpaid, their hours don’t count; if they’re paid, their hours count.
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