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Syam Adusumilli
Adjacent Gaps · ADJ.06

Executive Summary: The Seasonal Agricultural Workforce: Coverage That Cannot Follow Work That Moves

By Syam Adusumilli · 2 min read
Executive Summary Read the full article.

ADJ.06 — Adjacent
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Migrant and seasonal agricultural workers, estimated at 2.4 million by the National Center for Farmworker Health, work in employment patterns that cross state lines during ACA marketplace open enrollment windows. The coverage architecture was designed for a worker who lives in one state, works for one employer, enrolls during one open enrollment period, and uses one provider network. The seasonal agricultural worker does none of these things.

ACA marketplace enrollment runs November 1 through January 15 for most states. The agricultural labor calendar runs from late-winter planting through fall harvest across geographic regions that migrate northward with the growing season. A plan purchased in the Texas marketplace is not available to a member who moves to Washington; the marketplace architecture is state-based by design and structurally incompatible with a mobile workforce. The H-2A agricultural guest worker visa program brings approximately 370,000 workers annually who are not eligible for ACA marketplace coverage under current CMS guidance, have no employer-sponsored coverage obligation under the H-2A program beyond workers’ compensation and housing, and have no Medicaid eligibility. Domestic agricultural workers face the calendar and geography barriers. Undocumented workers are excluded from all three mechanisms. Each sub-population has a different legal barrier; all three share the same working conditions and occupational health exposure.

The QSEHRA is available to domestic agricultural workers at employers below 50 FTEs that do not maintain a group health plan, with 2025 annual limits of $6,350 for self-only and $12,800 for family coverage. The practical barrier is that many agricultural workers are employed through labor contractors rather than directly by the farm, and the contractor may not offer any benefit mechanism. DPC membership at $75 to $100 per month per worker, funded by the employer or contractor, provides primary care without the enrollment calendar and geography barriers that make the ACA marketplace functionally unavailable to a mobile workforce. For an agricultural employer paying $15 to $20 per hour in wages, DPC adds approximately $0.60 to $0.80 per hour to the labor cost.