"The only ways to safely circumvent [the ACA requirement to offer] such benefits to a short-timer or summer intern would be if: [1] The person could be legitimately categorized as a seasonal worker which means that their job can only, by its very nature and definition, be accomplished during a recurring season.... [2] the person will work less than 90 days; or [3] the person will be working less than 30 hours per week. Many [employers] are opting to limit summer interns to a maximum of 29.5 hours a week in order to avoid this issue.... Others are limiting summer interns to 89 or less days to accomplish the same goal. However, that day limit also means you cannot subsequently hire that summer intern inside of 13 weeks[.]"