Hours, not headcount, drive every decision.
- A small full-time core and a large part-time bench
- Tips on top of a full state minimum wage
- Several locations, sometimes under related owners
Most payrolls here pair a small full-time core of managers, chefs and leads with a large part-time bench of servers, bussers, hosts and housekeepers. Schedules move with reservations and the season, and people leave and come back. Each pattern touches plan eligibility, the federal employer-size count, or both.
Pay adds a second layer. Washington doesn't let tips count toward the state minimum wage, so a server's hourly rate must meet the full minimum before tips. That matters when you pick an affordability method.
Four levers we pull for restaurants and hotels.
Settle your ACA status from a year of hours.
Count hours before you design anything.
For each month of the prior calendar year, add full-time employees (130 or more hours of service) to FTEs: everyone else's hours, capping each person at 120, divided by 120. Paid vacation, holiday and sick hours count, and companies under common ownership are combined. Average the twelve months, or let the FTE calculator do it.
Illustrative: a restaurant group has 38 full-time employees and 45 part-timers averaging 64 hours a month. Those hours total 2,880, or 24 FTEs. If that holds all year, the group averages 62 and is an applicable large employer the following year, though only 38 people work full-time.
Measure swing schedules with a look-back.
For large employers, it settles who gets an offer.
A new hire you expect to work full-time, and who isn't seasonal, is assessed month by month, so don't default every server into a look-back. New variable-hour, part-time and seasonal hires can be measured over 3 to 12 months. Average 30 or more hours a week and they're full-time for a stability period of at least six months, never shorter than the measurement period, after an administrative period of up to 90 days.
Keep the group plan for the core and give part-timers an allowance.
An ICHRA can run by class beside your group plan.
With an ICHRA, you set a monthly allowance and each employee buys, and must enroll in, individual coverage. Full-time staff can keep the group plan while the part-time class gets the allowance. That split triggers a minimum class size for the ICHRA class: 10 employees for an employer with fewer than 100. A seasonal class is exempt. Written notice is due at least 90 days before the plan year.
Give the part-time bench something to elect.
Employee-paid coverage that protects a paycheck.
Accident, disability and hospital coverage can be offered as voluntary benefits, employee-paid through payroll deduction. That gives hourly staff something to elect, subject to each carrier's eligibility rules. It supplements medical coverage, and on-the-job injuries for L&I-covered workers still go through L&I.
A benefits year planned around the rush.
January: settle last year's count.
Average the prior year's monthly totals to see whether the large-employer rules apply. If you topped 50 for 120 days or fewer and the extra staff in that stretch were seasonal workers, you aren't treated as large. Have payroll or your tax adviser confirm.
About 90 days out: quote and model.
Aim for an effective date outside patio season and the holidays. We quote Premera Blue Cross, Regence BlueShield, Asuris Northwest Health, Kaiser Permanente and UnitedHealthcare, add level-funded options where underwriting allows, and model each class's cost.
Enroll at shift change.
We run short sessions at shift change, in person around Puget Sound or by video statewide, plus one-on-one calls for overnight and housekeeping staff. Education is at no extra fee for client teams.
After go-live: keep the hiring flow moving.
Enrollment never fully closes. Your admin updates Employee Navigator, we push carrier changes, and we coordinate a third-party COBRA administrator for departures. Vendor fees may apply.
Five things to send us.
A census with home ZIPs
Date of birth, home ZIP and coverage tier per employee. The census page has a template.
Twelve months of hours
Monthly hours by employee for last calendar year.
Pay type by role
Tipped, hourly or salaried. It shapes the affordability method and any classes.
Locations and owners
Every location, plus related companies under common ownership.
Your current plan
The renewal and summary of benefits and coverage, or a note that this is your first plan.
What owners and GMs ask us.
A line cook left in spring and came back in the fall. New hire or returning employee?
For ACA purposes, someone with 13 or more consecutive weeks of no hours of service can be treated as a new employee. An optional rule of parity also allows a break of four weeks or more when it's longer than their previous stretch of employment. Have payroll or your ACA vendor apply the rule your plan uses.
Do tips change whether our coverage counts as affordable?
It depends on the safe harbor. W-2 wages, rate of pay (the hourly rate times 130) and the federal poverty line start from different figures, so results can change with the method. 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. Have payroll or your ACA vendor apply your chosen method, and use our affordability calculator as a first check.
Most of our staff are part-time. Do we have to offer them coverage?
Under 50 full-time employees plus FTEs, federal law doesn't require an offer, and Washington adds no employer mandate. For an applicable large employer, part-timers who average 30 or more hours under your measurement method count as full-time for the stability period. Our ACA compliance page covers offers and reporting.
Where these rules come from.
IRS guidance on ALE status, identifying full-time employees and employer shared responsibility. L&I on tips and service charges. HealthCare.gov on individual coverage HRAs. General information, not legal or tax advice.
Bring us a year of schedules.
Send the census, last year's monthly hours and your current renewal. We'll return the employer-size math, quotes and a rollout plan that stays out of the rush. No obligation.