Seasonal and part-time new hires can be measured over an initial measurement period, because their hours are not expected to reach 30 a week on a steady basis.
A seasonal position is one with customary annual employment of six months or less, usually starting around the same time each year. The initial measurement period gives these hires a fair test.
A part-time hire is someone you reasonably expect to work fewer than 30 hours a week. They can be measured over an initial period and will not be treated as full-time unless the average shows it.
The initial measurement period and administrative period together cannot run past the end of the first calendar month on or after the first anniversary of the start date.
Sources: 26 CFR § 54.4980H-1; 26 CFR § 54.4980H-3. General information, not legal advice.
A town recreation department hires a pool attendant for a position with customary annual employment of about four months, May through August.
The position is seasonal, so the employer can use an initial measurement period. Averaged over a 12-month window, the attendant’s summer hours fall well below 30 a week, so the attendant is not full-time for the stability period.
Confirm customary annual employment is six months or less.
Set an initial measurement period of three to twelve months.
Total hours over the window.
Record the result and apply the stability period.
Where it goes wrong. Assuming any short-term hire is seasonal without checking the position’s customary annual employment.
Only if the position’s customary annual employment is six months or less. A position that runs year-round with temporary extra staff is judged on its own facts.
They count in the monthly figures, with a separate exception for employers whose workforce exceeds 50 for 120 days or fewer a year because of seasonal workers.
The measurement period will show it. If the average reaches 30 hours the person is full-time for the stability period that follows.
If the break meets the rehire rule, yes. Otherwise prior employment continues.
Only if hours are uncertain. A hire expected to work under 30 hours can be classified part-time and measured.
Plan-specific questions belong with ERISA counsel, and we will bring them in.
A measurement period that ends a few weeks before open enrollment, followed by an administrative period, lets you total hours, notify employees and enroll them in one motion.
A stability period of 12 months that runs with the plan year keeps eligibility and the benefit calendar in step, and avoids offering coverage for part of a plan year.
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