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

Jeremy Harkins · Accepted Answer

Yes — if those 40 people are employees of your church, Medicare's 20-employee rule would generally apply even though only 7 qualify for the employer health plan.

Medicare counts full-time and part-time employees, not just the employees who are eligible for or enrolled in the health insurance.

The employer generally meets the rule if it has at least 20 employees for 20 or more calendar weeks in the current or previous year. The weeks do not have to be consecutive.

There is one additional question for churches: Who is considered the employer? Medicare does not automatically combine employees from every church in a denomination, diocese, or church organization. If your coverage is through a church-wide or multi-employer health plan, those rules need to be checked separately.

So in this example, don't count only the 7 people who receive health benefits. First confirm that the 40 workers are employees of the same employer and whether the church participates in a larger multi-employer plan.

If the 20-employee rule applies and your coverage is based on current employment, the employer health plan generally pays first and Medicare pays second.

Jennifer Paxton · 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.

Rick Bechtel · Answer

Yes.  The 20-employee rule applies to the number of employees covered by the employer's group plan.

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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