If an ALE member uses the 98% offer method, it is not required to complete the "Section 4980H Full-Time Employee Count for ALE Member" in Part III, column (b).
From <https://www.irs.gov/instructions/i109495c#idm139957201480640>
If an ALE member uses the 98% offer method, it is not required to complete the "Section 4980H Full-Time Employee Count for ALE Member" in Part III, column (b).