If you manage ACA compliance for a staffing firm, you know the drill: tracking eligibility for variable-hour employees feels like trying to balance a game where the rules change mid-play. Between shifting schedules, rehire rules, and measurement periods, it’s no wonder ACA reporting has become one of the biggest headaches in the industry. 

The stakes are high—missteps can trigger costly IRS penalties. But the good news? With the right tools and automation, staffing firms can finally get ACA compliance right, without drowning in spreadsheets or sleepless nights. 

Let’s break down why variable-hour tracking is so complex, where firms often slip, and how automation can transform ACA compliance from a constant burden into a manageable process. 

Why Variable-Hour Tracking Is So Complex 

Staffing firms live in the land of unpredictable schedules. Unlike traditional employers with a steady full-time workforce, staffing companies have to account for employees who start and stop assignments, work irregular hours, or return seasonally. That’s where ACA’s rules add layers of complexity. 

1. Eligibility Tracking 

• Under ACA rules, employees averaging 30+ hours per week must be offered coverage. 

• To determine that, firms must track measurement periods—often 12 months—to calculate if an employee should be considered full-time. 

• For staffing firms, with fluctuating hours and short-term assignments, this is far more complicated than it looks on paper. 

2. Rehire Rules 

• ACA’s “break-in-service” rules require careful attention. If an employee returns after 13 weeks (26 for educational organizations), they can be treated as a new hire. If they come back sooner, prior service hours must be counted toward eligibility. 

• Staffing firms see this constantly with seasonal workers, event staff, or employees who pick up occasional shifts. One missed rehire window can put compliance at risk. 

3. Measurement Periods 

• Firms often juggle multiple measurement periods: initial periods for new hires, plus standard periods for ongoing employees. 

• With a high-turnover, variable-hour workforce, it’s easy to lose track of who belongs in which category—and that’s where mistakes happen. 

Every one of these rules requires precise, consistent data collection. For staffing firms, managing that manually is like trying to juggle flaming batons—possible for a while, but eventually something’s going to drop. 

Where Staffing Firms Slip Up 

Even the most diligent HR teams make mistakes when they’re relying on spreadsheets and manual processes. The most common pitfalls we see include: 

• Misclassifying variable-hour employees as part-time when they’ve crossed eligibility thresholds. 

• Missing rehire windows, which can lead to coverage gaps and penalties. 

• Inconsistent tracking of measurement periods, leaving firms exposed when the IRS reviews filings. 

If any of this sounds familiar, you’re not alone. We’ve seen it firsthand—and collected some of the most common mistakes in our resource on Avoiding Common ACA Pitfalls. 

The reality is that ACA compliance isn’t about effort—it’s about systems. Without the right infrastructure, even great teams can find themselves out of compliance. 

Automation as the Solution 

The simplest way to reduce variable-hour headaches? Automate. 

Reduce Manual Work 

An automated system tracks hours, eligibility, and rehire rules in real time, eliminating the need for HR teams to constantly update spreadsheets or chase down missing data. 

Increase Accuracy 

With built-in logic, automation applies ACA rules consistently—no second-guessing, no forgotten rehire dates, no errors that lead to IRS notices. 

Save Time & Stress 

Automation doesn’t replace people—it empowers them. Instead of pouring hours into manual tracking, your team can focus on higher-value work like placements, client relationships, and employee support. 

In short: automation takes ACA compliance from “always urgent” to “under control.” 

Why 2025 Is the Right Time to Act 

ACA compliance is always evolving, and 2025 brings new opportunities for staffing firms to modernize. With the Paperwork Burden Reduction Act and the Employer Reporting Improvement Act, reporting is set to become more streamlined. That means fewer forms and more accurate IRS validations—but it also means less margin for error. 

Firms that invest in automation now will be positioned to take full advantage of this new flexibility, while avoiding the pitfalls that come with manual processes. 

Variable-hour tracking has been a thorn in the side of staffing firms since the ACA began. But it doesn’t have to be. With the right automation, staffing firms can finally: 

• Get eligibility tracking right. 
• Stay ahead of rehire rules. 
• Eliminate costly compliance errors. 

Want to see where most staffing firms get tripped up? Download our free guide: Common ACA Pitfalls & How to Avoid Them. 

And for a few real-world cautionary tales, check out our ACA Compliance Horror Stories. 

Because when it comes to ACA compliance, you don’t need more headaches—you need a smarter playbook.