"The IRS provides no clear methodology for counting and tracking resident assistant hours.... [W]here hours of service are particularly difficult to identify or track, an employer should use a 'reasonable method of crediting hours of service that is consistent with [Code] section 4980H.' The IRS has also offered the following guidance, which is illustrative (albeit not quite on point): The 'adjunct faculty' safe harbor.... 'On call' employees."  MORE >>