Headcount is the easy part.
Each of these can move when you add people or an address.
- ACA status: last calendar year's average of full-time staff and full-time equivalents
- Small-group status: Washington's own 1-to-50 count, with affiliated companies as one employer
- Network fit: providers near where new staff live, not just where they work
- Service area: whether the current carrier reaches the new location
- Rating area: Washington has nine, and small-group rates can vary by area
- Administration: who enters the new site's hires and sends us changes
The two size tests are easy to confuse. The ACA test averages last year's monthly counts: full-time means 130 hours of service a month, and other employees' hours are totaled, capped at 120 per person, then divided by 120. Washington's small-group definition uses its own count. Crossing 50 on a Tuesday in June settles neither.
Illustrative: a 38-person Tacoma distributor plans a Spokane warehouse with 15 hires. Those hires may not change this year's ACA status, since the test looks back a year, but a full year at 53 full-time employees would make the company an applicable large employer the following year. The owner also needs providers near Spokane-area homes.
Four moves for a business that's adding people.
Count every month you're hiring
Don't wait for year-end to learn your ACA status.
Run the numbers monthly with our FTE calculator, so a year of hiring doesn't surprise you in January.
If you'll be an applicable large employer next year, start the ACA compliance work now. The employee's share of the lowest-cost self-only plan with minimum value can't exceed 9.96% for 2026 plan years or 10.22% for 2027, measured with one of the IRS safe harbors: W-2 wages, rate of pay or the federal poverty line. The affordability calculator runs it.
Check networks by home ZIP code
Employees see doctors near where they live.
Check the home ZIP codes of current staff at the new site, or the area you'll recruit from, against each carrier's network and service area. A plan that works around your first office can be thin near the second, and a second plan option or a different carrier may fill the gap.
Keep contribution classes consistent
Same class, same employer share, wherever people work.
If new-site staff get a different deal, it should come from a defined class, not paperwork drift. An ICHRA can set classes by state or rating area, each with its own allowance. When some classes keep the group plan and others get an ICHRA, a minimum class size applies, 10 employees for employers with fewer than 100, though a class defined by a whole state is exempt.
Re-test the funding at the new size
Growth is a natural point to compare funding methods.
A level-funded plan is priced on your own group, with a fixed monthly payment covering a claims fund, stop-loss insurance and administration. Underwriting can raise the price or decline the group, renewals follow your own claims, and contract terms vary by carrier. We quote UnitedHealthcare, Nationwide, Angle Health and Cigna beside your small-group renewal on the same census.
From signed lease to the first enrollment at the new site.
When the expansion is decided
Tell us the timeline and the new address. Size-test and network problems are easiest to solve this early.
About 90 days before the first hires
Check networks and service areas near the new site, name a payroll contact there, and decide whether one plan still fits both locations.
About 60 days before
Set eligibility and contributions for new staff. If the current plan doesn't reach the area, we start quoting alternatives now, since underwriting and enrollment take time.
Ahead of the first enrollment deadline
Schedule education where the new team works, in person around Puget Sound or by phone and video statewide, at no extra fee for client teams. Train the site's administrator in Employee Navigator.
Every year-end
Re-run the full-year average. It sets your ACA status for the coming year.
What to send, and what to watch.
Send us
Your hiring plan by month and location, a current census with home ZIP codes, the new site's address, the ownership of any related companies, and your current plan summary and renewal date.
Watch for
Assuming the new location will plug in on its own. We handle carrier changes, but confirm how each site's hires reach payroll, Employee Navigator and the carrier instead of assuming the systems connect.
What expanding employers ask us.
We're opening an office in another state. Can our Washington plan cover those employees?
Sometimes. It depends on the carrier's network and service area where those employees live. If the group plan can't reach them, an ICHRA class for that state is one option, and a class defined by a whole state is exempt from the minimum class size. We check both before you hire.
We bought another company. Do its employees count toward our size?
If the companies share common ownership, they're combined for the ACA employer-size test, and affiliated companies count as one employer for Washington small group. Have your tax adviser confirm the ownership analysis before you rely on a number.
Summer hiring takes us past 50 every year. Are we an applicable large employer?
Not necessarily. If the workforce tops 50 for 120 days or fewer in the year and the extra workers in that stretch were seasonal, you aren't treated as over 50. Keep payroll records that show it.
When do we leave the small-group market?
Washington's small-group market covers employers that averaged 1 to 50 employees in the previous calendar year. Past that, the small-group rating rules, which limit rate variation to area, family size, age and wellness activities, no longer apply, so expect a different renewal conversation.
Where the size rules come from.
IRS: determining applicable large employer status. IRS: identifying full-time employees. Washington OIC: small business health plan options. General information, not legal or tax advice.
Plan the benefits side of the expansion.
We'll map the size tests and networks before the first offer letter goes out. No obligation.