500 Employee Eligibility

Do I count both full-time and part-time employees to determine if I am under the 500 employee maximum threshold?

For the purposes of loan eligibility, yes. For the purposes of loan forgiveness, no. The CARES Act defines the term employee to include “individuals employed on a full-time, part-time, or other basis.”

By contrast, for purposes of loan forgiveness, the CARES Act uses the standard of “full time equivalent employees” to determine the extent to which the loan forgiveness amount will be reduced in the event of workforce reductions.

Linked here and pasted below is the text from the official question and answer document published by the Department of the Treasury, which you should reference:
https://home.treasury.gov/system/files/136/Paycheck-Protection-Program-Frequently-Asked-Questions.pdf

Below is the official question from Q36 as of May 14, 2020

36. Question: To determine borrower eligibility under the 500-employee or other applicable threshold established by the CARES Act, must a borrower count all employees or only full-time equivalent employees?

Below is the official answer from Q36 as of May 14, 2020

Answer: For purposes of loan eligibility, the CARES Act defines the term employee to include “individuals employed on a full-time, part-time, or other basis.” A borrower must therefore calculate the total number of employees, including part-time employees, when determining their employee headcount for purposes of the eligibility threshold. For example, if a borrower has 200 full-time employees and 50 part-time employees each working 10 hours per week, the borrower has a total of 250 employees. By contrast, for purposes of loan forgiveness, the CARES Act uses the standard of “fulltime equivalent employees” to determine the extent to which the loan forgiveness amount will be reduced in the event of workforce reductions.

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