90 Day Waiting Period Guidelines Issued

Last week (02/20/2014), the ACA's "trinity" of compliance and enforcement (i.e., departments of Health/Human Services; Labor; Treasury) jointly issued both FINAL and PROPOSED regulations pertaining to the ACA provision addressing new hire waiting period limitations.  This week's post will focus primarily on the FINAL regulations.

Let me start by defining what it is that we received guidance on - the so called "90 day waiting period limitation".  For readers not familiar with this issue...the waiting period is the period of time allowed to pass before health insurance coverage can become effective for an otherwise eligible employee (and his/her dependents).  Per the Affordable Care Act (ACA), this period of time is now restricted, and can be NO LONGER than 90 days.  Thus, the latest possible time that coverage can take effect is the 91st day from the initial date of hire.  This affects any employer that has a waiting period that is:

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