A headcount that follows the crop.
- A year-round core plus seasonal crews
- Related companies under common ownership
- H-2A or other mixed workforces
- Long drives to in-network care
- Dawn starts and language needs
Farms, orchards and ranches keep a year-round core of managers, operators, mechanics and office staff, then add seasonal crews for planting, thinning or harvest, some returning and some new. A packing shed or hauling company under the same owners is combined with the farm for the ACA count, and H-2A crews need their own employment and plan-eligibility review.
Harvest counts toward 50, with one narrow exception.
Applicable large employer status looks back at last calendar year: full-time employees plus full-time equivalents, averaged over twelve months, with harvest hours counted like any others. Run the months through our full-time equivalent calculator.
The exception: you aren't treated as an applicable large employer if your full-time workforce, counting equivalents, runs above 50 for no more than 120 days in the year and everyone above 50 in that window was a seasonal worker. The IRS definition of seasonal worker includes seasonal farm labor.
Illustrative: an orchard keeps 45 full-time employees all year and adds 60 seasonal pickers for about 100 days. Its yearly average lands above 50, but the workforce tops 50 only during those 100 days and every worker above 50 is seasonal, so the exception may apply. A harvest past 120 days, or a peak filled with year-round hires, breaks it. Have payroll or your tax adviser confirm the monthly counts.
Four decisions that shape a farm plan.
Who the plan is built around
Start with the year-round staff.
Set eligibility, contribution and a waiting period that stays inside 90 days for the core, then decide how seasonal workers fit. Under 50, federal law doesn't require an offer and Washington adds no mandate. As an applicable large employer, your measurement method decides when a seasonal hire who averages 30 or more hours a week counts as full-time.
Network by where crews live
Map the clinics before comparing premiums.
A crew may be a long drive from the nearest in-network clinic, hospital or pharmacy, so check each employee's home ZIP code against each carrier's network. We quote group medical with Premera Blue Cross, Regence BlueShield, Asuris Northwest Health, Kaiser Permanente and UnitedHealthcare. Give dental and vision the same check: annual limits and provider access next to the premium.
A separate track for the season
Classes and allowances instead of one plan for all.
An ICHRA can give seasonal workers their own class and monthly allowance, exempt from the minimum class-size rule. Classes can also follow rating area, useful when crews work in two parts of the state. Employees buy individual coverage, must stay enrolled in it and need written notice at least 90 days before the plan year.
Income protection for physical work
Protect the paycheck, not just the clinic visit.
Disability coverage replaces part of a paycheck, and accident or hospital coverage, employee-paid through payroll deduction, pays cash after a covered event. On-the-job injuries for L&I-covered workers go through L&I, so these plans sit alongside medical and workers' comp, not in place of them. Explain what triggers a payment and what each plan excludes.
Work backward from harvest.
After harvest: run the year's count
Once the crews leave, total each month's full-time employees and equivalent hours for this calendar year. That count sets your ACA status for the next one.
Winter: set the rules and quote
Settle eligibility and contribution for the core, compare group, level-funded and HRA options on one census, and send any HRA notice at least 90 days before the plan year.
Before seasonal hiring: build the hire sheet
Give each eligible worker a start date, an eligibility call, a deadline to elect and a named contact. A worker who has gone 13 or more straight weeks without an hour of service can come back as a new hire. The optional rule of parity also lets a shorter break count, if it's at least four weeks and longer than the stretch they worked before.
Before the rush: enroll in short sessions
Meet before the busiest stretch, keep it brief and take questions one on one afterward by phone or live video. Confirm any interpretation before you announce it.
What to send, and what we'll ask.
Send
A year-round census with dates of birth, home ZIP codes and coverage tiers, last year's monthly headcount, your plan summary if you have one, and a target start date. Our employee census page has the format.
We'll ask
Who returns each season and for how long, whether related companies share ownership, whether you hire through H-2A, and which clinics your crews use now.
What agricultural employers ask.
Do we have to offer the plan to H-2A workers?
It depends on the plan's eligibility terms and, if you're an applicable large employer, how the ACA rules apply to those employees. Settle it in a separate employment and eligibility review with payroll or counsel, then we build the plan around the answer.
We average under 50. Is a QSEHRA worth a look?
It can be, if you also offer no group health plan, which rules out stand-alone dental or vision plans and a health FSA. For 2026 the limits are $6,450 for self-only and $13,100 for family coverage, seasonal and part-time staff can be left out, and written notice is due at least 90 days before the year. See our HRA strategies.
Does a level-funded plan make sense for a farm?
It can for a stable year-round core. It's underwritten on your own group, with one fixed monthly payment for a claims fund, stop-loss insurance and administration. Underwriting may come back higher or decline the group, renewals track your claims, and a surplus refund is possible, not promised.
Official references: IRS applicable large employer rules, IRS guidance on identifying full-time employees, the DOL 90-day waiting period limit, HealthCare.gov on the ICHRA and the QSEHRA, and the Office of the Insurance Commissioner on small business plans. General information, not legal or tax advice.
Send last year's monthly headcount. We'll start there.
Add a year-round census and your renewal if you have one. No obligation.