How will seasonal employees factor into whether an employer is a “large employer”?
An employer will not be considered a “large employer” under the Affordable Care Act if its workforce exceeds 50 full-time employees for 120 days or fewer during a calendar year and the employees in excess of 50 employed during such 120-day period were seasonal workers. “Seasonal workers” are defined as workers who perform labor or services on a seasonal basis as defined by the Secretary of Labor and include retail workers employed exclusively during holiday seasons.
