A seasonal employee is someone who works full-time hours (30+ per week or 130+ per month), but only for a limited period each year, typically due to a recurring seasonal need—such as during holiday retail, summer camps, or harvest seasons.
Under the ACA, seasonal employees are treated differently when determining Applicable Large Employer (ALE) status.
✅ Seasonal Worker Exception (for ALE status):
If an employer exceeds 50 full-time employees (including FTEs) for no more than 120 days in a calendar year, and the employees in excess of 50 during that time are seasonal workers, the employer may not be considered an ALE for that year.
However, once you’re determined to be an ALE, seasonal employees must be tracked just like any other employee for full-time status and offer of coverage purposes.
🧠 Key Points:
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Seasonal employees can work full-time hours but don’t need to be offered coverage if they won’t meet ACA full-time status based on your measurement method
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The 120-day rule applies only when determining ALE status