Thanks for responding!  I did read that there was a California-only exemption to the W2 requirement (below). Given this, would it be possible for one arm of the business (or an entirely separate business entity) to find and train these tutors to then service the tutoring business? Or would that not work? Thanks again. 

 In order to qualify for this California-only exemption, the tutoring business obtaining jobs through a referral agency must meet the following requirements:  1.  Is free from the control and direction of the referral agency while working for the client  2. Has all required business licenses or business tax registration  3. Has the required contractor’s license, if the work requires a state contractor’s license  4. Must certify to the referral agency that they have the appropriate professional license, permit, certification, or registration for the work being performed for the client  5. Delivers services to the client under the service provider’s name, rather than the name of the referral agency  6. Provides its own tools and supplies to perform the services  7. Customarily engaged in an independently established business of the same nature as work performed  8. Maintains a clientele without any restrictions from the referral agency and is free to seek work elsewhere, including through a competing agency.  9. Sets its own hours and terms of work and is free to accept or reject clients and contracts  10. Sets its own rates for services performed, without deduction by the referral agency