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ACA Compliance Resources

Full-Time Temporary Employees – When are they eligible under the ACA?


Employees should be eligible for coverage after a full-time waiting period, not to exceed 90 days. There are some allowances for “seasonal” employees & workers, however, this does not apply to assignments via a staffing company. The seasonal limitation of 6 months of employment is generally accepted. There is a great SHRM article that discusses this in detail:

The ACA and Staffing: One Size Does Not Fit All

“… the staffing firm cannot classify a new employee who will work a full-time schedule as a variable-hour employee just because the employee is not expected to be there for the full year measurement period.”

Our guidance would be to offer coverage to all employees reasonably expected to work in excess of 30 hours/week regardless of the anticipated length of assignment after the full-time waiting period has expired.


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Last Review: 6/12/2022 – Revision: 0.0

Applies To: ACA6 Compliance Solution

Categories:  ACA Reporting Requirements; Employee Classification; Eligibility Reporting

Keywords: Temp, Staffing

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