How do I count the 12 months needed to qualify for CFRA for a seasonal-turned-regular employee who’s met the 1,250-hours of work requirement?

This employee would be eligible for California Family Rights Act (CFRA) leave as long as they worked at least 12 months for the company (at some point in the past) both as a seasonal or regular employee.

A two-part test determines if an employee is eligible for CFRA leave: 12 months of employment, and 1,250 hours of work in the 12 months preceding the requested time off from work.

The California Code Regulations, at Title 2, Section 11087(g), states that an “eligible employee” is an employee “who has been employed for a total of at least 12 months (52 weeks) with the employer at any time prior to the commencement of a CFRA leave, and who has