How do seasonal workers count toward the ACA 50 FTE employer mandate threshold?

Seasonal workers who are employed for 120 days or fewer per year are treated as seasonal workers under ACA rules. If a Florida business exceeds 50 FTEs only because of these short-term seasonal employees — and the excess only occurs for 120 days or fewer — the business is not an Applicable Large Employer and the employer mandate does not apply. A landscaping company that swells from 35 to 60 employees only during spring planting season is a classic example.

Can Florida small businesses offer health insurance to seasonal employees who return each year?

Yes. Employers can voluntarily offer group health coverage to seasonal employees — there is no rule prohibiting it. Returning seasonal workers who come back each year for a predictable season can be enrolled in the group plan for the months they are employed. This can be a meaningful retention tool for businesses that rely on experienced seasonal workers returning year after year.

What are the health insurance options for seasonal workers in Florida who are not covered by an employer plan?

Seasonal workers without employer coverage can access individual ACA Marketplace plans. Job loss or reduction in hours is a qualifying life event that triggers a Special Enrollment Period — so a seasonal worker who loses job-based coverage at the end of the season has 60 days to enroll in a Marketplace plan. Income-based premium tax credits apply. Between seasons, many seasonal workers maintain Marketplace coverage or go uninsured if they have other household coverage.

Updated April 2026 · Florida Plan Finder · Licensed Florida Health Insurance Agency

Health Insurance for Seasonal Employees at Florida Small Businesses

Q: Do Florida small businesses have to offer health insurance to seasonal employees?

Florida small businesses under 50 FTEs are not required to offer health insurance to any employees — seasonal or otherwise. Businesses that reach 50 FTEs only due to seasonal hiring may qualify for the ACA seasonal worker exception: if the employer exceeds 50 FTEs for 120 days or fewer during the year, and the employees pushing it over 50 are seasonal, the employer is not considered an ALE and the mandate does not apply.

Florida's economy is profoundly seasonal. Tourism peaks in winter and summer. Agriculture employs thousands in spring and fall harvest windows. Landscaping swells in spring. Charter fishing, resort hospitality, and outdoor recreation all have high and low seasons. Small businesses that staff up significantly for seasonal peaks need to understand how seasonal employees affect ACA employer mandate obligations, FTE counts, and group plan eligibility — and what options exist for providing or supporting seasonal worker coverage.

Related resources:

ACA Employer Mandate Part-Time Employee Coverage Charter Fishing Business Coverage

ACA Seasonal Worker Exception

Under ACA rules, a Florida employer is not considered an Applicable Large Employer (ALE) — even if it temporarily exceeds 50 FTEs — if the following conditions are met:

The employer exceeds 50 FTEs for 120 days or fewer during the calendar year
The employees pushing the count over 50 are seasonal workers

A landscaping company with 35 year-round staff that hires 20 additional workers for 90 days each spring qualifies for this exception. A tourist resort that swells to 65 employees for just the summer season may also qualify if the seasonal employees are the ones pushing it over 50.

ACA Seasonal vs. Part-Time FTE Counting

Employee Type	ACA FTE Impact	Coverage Obligation
Seasonal worker (≤120 days/year)	Counts toward FTE during months employed	No mandate if seasonal exception applies
Full-time year-round (30+ hrs/wk)	Counts as 1 FTE each month	Must be offered coverage if ALE
Part-time year-round (<30 hrs/wk)	Hours ÷ 120 = fractional FTE	No obligation, but counted toward threshold

Frequently Asked Questions

Do Florida small businesses have to offer health insurance to seasonal employees?

No — and businesses that only exceed 50 FTEs due to seasonal hiring (for 120 days or fewer) qualify for the seasonal worker exception to the employer mandate.

How do seasonal workers count toward the ACA 50 FTE threshold?

Seasonal workers count toward FTEs in the months they are employed. But if exceeding 50 FTEs only occurs for 120 days or fewer and the excess is due to seasonal employees, the employer mandate does not apply.

Can Florida small businesses offer health insurance to returning seasonal employees?

Yes — employers can voluntarily include seasonal employees in the group plan during their employment period. This is a retention tool for businesses that rely on the same experienced seasonal workers returning year after year.

What health insurance options exist for seasonal workers not covered by an employer?

ACA Marketplace individual plans — losing job-based coverage is a qualifying life event. Seasonal workers have 60 days to enroll. Premium tax credits apply based on annual income.

Get Group Health Insurance Options for Your Florida Seasonal Business

A licensed broker can help you structure coverage for year-round staff and seasonal workers.

Get Seasonal Business Quotes

Florida Plan Finder — Licensed Florida Health Insurance Agency · (877) 224-8539 · License #L088529
ACA seasonal worker exception has specific requirements — confirm your eligibility with a licensed broker or benefits attorney.