Three ways a team stops fitting the standard plan.
- A written method for measuring variable hours
- Rehire rules applied the same way each season
- Networks checked at every remote employee's home
- Location and language needs confirmed before enrollment
Hours that move. When schedules shift weekly, you need a written way to decide who is full-time. For the ACA, that's 130 hours of service in a month, roughly 30 a week, and paid leave counts.
Seasons that spike. A busy season can push headcount past 50 for a few months, but the employer-size test uses the prior calendar year's average, combines commonly owned companies and has a narrow seasonal-worker exception.
Homes somewhere else. A remote hire in Bellingham or Bend may live outside a network built around your main office, and telehealth doesn't cover every visit. We meet in person around Puget Sound and work by phone and video statewide.
Four tools for a workforce that won't sit still.
A measurement method for variable hours
Measure first, then lock in status.
For a new hire whose hours will swing, or who is part-time or seasonal, you can track hours over a first stretch lasting anywhere from 3 to 12 months. Someone averaging 30 or more hours a week over it is then full-time throughout the stability period: at least 6 months, never shorter than the measuring stretch. An administrative period of up to 90 days sits between the two. Year-round full-time hires skip the look-back; their status is checked monthly.
Rehire rules, decided once
Know when a returning worker counts as new.
A returning employee can be treated as new after 13 or more consecutive weeks with no hours of service. Under the optional rule of parity, a break of at least 4 weeks also qualifies if it's longer than their previous stretch of work. Pick a rule, write it down and apply it every season.
An allowance instead of a plan seat
ICHRA and QSEHRA reach people a group plan misses.
An ICHRA can set different allowances for seasonal, part-time and full-time classes, or by state or rating area. Where a group plan stays for some classes, an employer under 100 generally needs 10 or more in an ICHRA class, though a part-time class faces that minimum only if full-timers keep the group plan, and seasonal and whole-state classes are exempt.
A QSEHRA suits employers under 50 offering no group health plan at all, not even stand-alone dental or vision coverage or a health FSA. The 2026 limits: $6,450 for one person, $13,100 for a family. Amounts can reflect age and family size, and you may leave out seasonal and part-time staff. Both arrangements need notice 90 or more days ahead of the year.
Networks chosen by where people live
Check the home ZIP code before the offer letter.
Before a remote hire starts, check the network at their home address. If it's thin, the choices are a broader network for everyone or an ICHRA class by state or rating area. Participation matters too: a carrier may require 75% of eligible employees, or all of them when a group has three or fewer, to enroll.
One variable-hour hire, from first shift to stability.
Illustrative: a variable-hour employee hired April 1, with a 6-month initial measurement period and a one-month administrative period.
April 1: classify the role
Is the job full-time and year-round, or variable, part-time or seasonal? That sets the method. Eligibility and any waiting period are separate questions, and the wait can't pass 90 days.
April to September: measure
Payroll tracks hours of service for six months, counting paid vacation, holidays and sick time.
October: administrative period
Total the hours, decide status and enroll. The rules allow up to 90 days; this employer uses one month.
November to April: stability period
Averaging 30 or more hours a week means full-time status for these 6 months, even if hours drop.
If they leave and come back
Check the break. Thirteen or more weeks without hours of service lets you treat them as new; the rule of parity can cover shorter breaks.
Two assumptions that cause trouble.
Crossing 50 in July doesn't settle it.
The test averages last year's monthly counts of full-time employees plus equivalents. If you topped 50 for 120 days or fewer and the extra people were seasonal workers, you aren't treated as over 50, and the IRS definition includes seasonal farm labor. See our agriculture page and full-time equivalent calculator.
Part-time staff aren't out of options.
Part-timers can get a class and allowance of their own under an ICHRA, and a QSEHRA may include or leave them out. Run the employee cost test first.
What employers with shifting teams ask us.
Does paid time off count toward the 130 hours?
Yes. Hours of service include hours paid, or owed, for work plus paid leave such as vacation, holidays and illness, so a paid week off still counts.
Our remote staff live in three states. One plan or several?
Check the network at each home first. If one plan works everywhere, keep it simple. If not, an ICHRA lets each person choose an individual plan in their own market.
How do you enroll people who never come to the office?
Live virtual sessions, one-on-one calls and online elections in Employee Navigator. Share locations and languages early so sessions are set before enrollment opens. Education is included at no extra fee for client teams.
Do we have to offer coverage at all?
Not under federal law if you're under 50, and Washington adds no employer mandate. For an applicable large employer, the employee's share of the lowest-cost self-only plan that provides minimum value can't exceed 9.96% for 2026 plan years. Try our affordability calculator and ACA compliance page.
Official sources: the IRS on applicable large employers and full-time employees, the Department of Labor on the 90-day waiting period limit, and HealthCare.gov on individual coverage HRAs and QSEHRAs. General information, not legal or tax advice.
Send the schedule, the season and the map.
A census with hours, hire dates and home ZIP codes lets us sort out who's eligible and what to quote. You don't need a current plan to start.