I work for a church with 40 employees, but only 7 are full-time and eligible for employer health insurance. Does Medicare’s 20-employee rule still apply?

Question

Jennifer Paxton · Accepted Answer

Yes, Mediare's 20-employee rule still applies. The rule looks at the total number of employees on the payroll, not just those enrolled in the group health plan. Since your church has 40 total employees, you meet or exceed the 20-employee threshold. Because you have 40 employees, your church's group health plan is considered the primary payer for employees who turn 65, and Medicare is the secondary payer. Employees eligible for Medicare can safely delay enrolling in Medicare Part B without facing late penalties.

Answered by Jennifer Paxton on August 26, 2026

Broker Licensed in SC, AK, AL & 47 other states

Answered by Jennifer Paxton Medicare Insurance Agent

Steven Litzsinger · Answer

Yes, Medicare's 20 employees or more rule applies in this situation. Regardless if the employees are Full Time or Part Time (not benefit eligible), they each count as 1 employee in calculating the number of employees. 

For Example:
2 Full Time Employees + 3 Part Time Employees = 5 Total Employees (1:1 Count on Employees)

The calculation is based on actual people and not be calculating Full Time Equivalents (FTE)s that is used for employer sponsored and ACA/marketplace calculation.

Mark Bilgere · Answer

Yes. As long as the people are actual employees and not contractors. Medicare does not consider part-time vs. full-time when counting the employees. In this case the employer plan would be primary and Medicare would be secondary.

Answered by Mark Bilgere on August 26, 2026

Broker Licensed in TX, AR, IN & LA, MN, NE & OK

Answered by Mark Bilgere Medicare Insurance Agent

Corey Bennett · Answer

Yes, the 20‑employee rule still applies. Your church counts all employees, not just the ones eligible for insurance.

I work for a church with 40 employees, but only 7 are full-time and eligible for employer health insurance. Does Medicare’s 20-employee rule still apply?

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I work for a church with 40 employees, but only 7 are full-time and eligible for employer health insurance. Does Medicare’s 20-employee rule still apply?

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