Sec 105 one-person coverage vs ICHRA

[SKSP]

My client wants to reimburse an employee for part of their health insurance premium. A one-person Sec 105 seems the simplest way to go.  But...there are actually three W-2 employees, one of whom is full-time.  Those other two employees both wish to decline coverage as they already have full coverage from their spouse.  I don't see a way to separate them into classes.

Do the two eligible non-participants prevent us from make adopting the one-person 105?  At a $100/day penalty, I don't want to mess it up.

Thanks in advance