Seasonal and Part-Time
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.
The three things to know.
Seasonal Employees
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.
Part-Time Employees
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.
Same Limits Apply
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 worked example.
A Summer Pool Attendant
A town recreation department hires a pool attendant for a position with customary annual employment of about four months, May through August.
What the Rule Produces
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.
Four steps to apply it.
1. Check the position
Confirm customary annual employment is six months or less.
2. Choose a window
Set an initial measurement period of three to twelve months.
3. Measure
Total hours over the window.
4. Classify
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.
The questions that come up next.
Is a holiday-season hire always seasonal?
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.
Does a seasonal hire count for large-employer status?
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.
What if a part-time hire’s hours grow?
The measurement period will show it. If the average reaches 30 hours the person is full-time for the stability period that follows.
Does a returning seasonal hire start over?
If the break meets the rehire rule, yes. Otherwise prior employment continues.
Is a part-time hire always measured over an initial period?
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.
Related pages on the look-back method.
Align Measurement to Open Enrollment
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.
Match Stability to the Plan Year
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.
The Full Look-Back Guide
Every rule, example and source behind this page, in one place.
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