No. The requirement is ten qualifying full-time positions for people other than the investor and the investor's spouse and children. Build the staffing model on genuine outside hires with defined roles and hours. Which counting methods are permitted also depends on whether the case is standalone or filed through a designated regional center.
Write the org chart before the marketing plan
List every intended position by title, hours, wage, and the month it starts, then ask whether revenue at that month supports the payroll. Positions that exist only in year five carry different evidentiary weight from those already filled. Where a role might be filled by a contractor or a part-timer, flag it for counsel rather than assuming it counts.
An honest chart with eleven funded roles is stronger than a hopeful one with twenty. Positions existing only in year five carry different evidentiary weight from those already filled, and a role that might be filled by a contractor or a part-timer should be flagged for counsel rather than assumed to count. The requirement is ten qualifying full-time positions for people other than the investor and the investor's spouse and children, so build the model on genuine outside hires with defined roles and hours.
An honest chart with eleven funded roles is stronger than a hopeful one with twenty, and it leaves room for a departure.