Seasonal Employees FAQ

June 14, 2018

What has changed about the way PERA evaluates seasonal positions?

Before January 1, 2015, if a single employee held more than one seasonal position with an employer, all of the positions that met PERA’s definition of seasonal were excluded. Similarly, if an employee held both a seasonal position and a part-time permanent position, eligibility for PERA membership was based on the facts of each position separately.

Effective Jan. 1, 2015 and updated in 2021, the seasonal exclusion applies only to employees whose sole employment is a seasonal position with a duration limited by the employer to 6 consecutive months or less in each period of work. A break of at least 30 days resets the seasonal exclusion for an employee. Therefore, if an employee returns to the same position the next season, after a 30 day break in employment, the seasonal exclusion continues to apply if the position is again limited in duration to 6 consecutive months.

Under the 2015 and 2021 PERA provisions, if an employee holds two positions with a single employer, one permanent and the other seasonal (duration of 6 consecutive months or less), the seasonal exclusion will not apply. The seasonal exclusion is only if the employee is solely in a seasonal position. For this example, pay from both positions is subject to the monthly threshold. A common example of this is when a school district employs a person as both a part-time paraprofessional and a coach.

We have a part-time employee who was enrolled in PERA. This individual also coaches baseball each spring. Can I exclude the coaching wages for this individual?

No, the employee’s coaching pay is subject to PERA deductions as of Jan 1, 2015 because the coaching job is not the sole position with a single employer.

An on-call employee for our City has been excluded from PERA because their earnings never exceed the monthly salary threshold. Now they have accepted a seasonal position as a golf course attendant with the City. How do we determine if they are eligible for PERA now?

Since they do not have a sole seasonal position, the seasonal exclusion does not apply. Watch for the pay from both positions to exceed the $425 monthly threshold. If pay exceeds the monthly threshold, enroll the employee with the paycheck that put their pay over $425 in a month.

We have a seasonal employee who is unexpectedly working longer than 6 months. Do we have to submit contributions back to when he first started?

No. If the original employment dates fit PERA’s definition of a seasonal position contributions should not go back to when the position began. However, when you first know that the duration of employment will exceed 6 consecutive months the seasonal exclusion expires. If their pay exceeds the monthly threshold at the time it is known they will work over 6 consecutive months, you must begin contributions immediately. Do not wait until 6 months has passed; the seasonal exclusion becomes invalid at the time it is first known that the position duration will be over 6 consecutive months.

A seasonal employee is starting on March 1. However, we do not know how long they will work for us. Can we exclude them as a seasonal employee?

No. In order to qualify for exemption from PERA membership as a seasonal employee, the employment period must be pre-determined to be 6 months or less. In this example, if no exclusions apply, you must enroll the employee into PERA immediately once their earnings exceed the monthly threshold.

If a seasonal employee is hired for another seasonal position after the first employment ends, do we need to enroll the employee in PERA?

When someone holds consecutive seasonal positions, eligibility is dependent on the length of the break between the two positions.

If there is a 30-day (or more) break between them, the 6-month window ‘resets’ and you look at the duration of each position independently. For example, if the first position had an employment period of 4 months, a break of 45 days occurred, and then the employment period for the second seasonal job was exactly 6 months, the employee is excluded from PERA under two separate seasonal employee exclusions.

On the other hand, if the break between the two positions is less than 30 days, the employment duration must be considered continuously. For example, if an employee’s first position was 4 months, a 15-day break occurred, and then they start working in a second seasonal job that will last exactly 6 months, the seasonal exclusion expires as soon as it is known they will work in the second position.

What about multiple seasonal positions? We have someone who plows snow for us in the winter and does road grading in the summer.

If the seasonal work is the employee’s only employment with your agency, it is possible this could be treated as two separate seasonal positions. You must look at the length of the break between the two positions. If there is at least a 30-day break between the end of snowplowing and the beginning of road grading (and then again between when the road grading ends and snowplowing begins again), then you can consider each a separate seasonal position.

However, if one or both of the breaks are less than 30 days, you must review the earnings of the employee and enroll him/her immediately if they are paid over $425 in a month. You should also ensure that the person is an employee rather than an independent contractor. For information on this, refer to the Independent Contractor or Employee Brochure and Worksheet.