"[1] If interns qualify as seasonal or variable-hour employees, clearly define them and state this in their offer letters.... [2] Closely track the work and hours of interns. Remember a long-term substitute should not replace hiring regular employees. [3] Measure your seasonal employees over a defined measurement period to know if they will become benefits-eligible if they remain employed.... [4] If you decide to hire interns after they complete their internship, offer benefits as appropriate[.]"  MORE >>