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Will Your Part-Time and Seasonal Employee Policy Result in an ACA Penalty?
Polsinelli PC 
[Guidance Overview] Sept. 6, 2016
"[S]ome employers have implemented policies to restrict part-time and seasonal employees (non-FTEs) from working an average of 30 or more hours per week. However, the IRS recently specified that these policies are not enough to avoid liability. Actual hours count -- even if performed in violation of an employer's policy."
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