ACA regs keep rolling along

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in Employment Law,Human Resources

Full implementation of the Affordable Care Act (ACA) health care reform law is mere months away, which means that the IRS and the Department of Health and Human Services have a lot of work to do in a short period of time. The latest regulations cover the 90-day waiting period for new employees and temporary reinsurance fees.

Waiting periods

Proposed regs, which apply to insured and self-insured grandfathered and non-grandfathered group health plans, use HIPAA’s definition of “waiting period.” Under these regs, the maximum waiting period coincides with the maximum length of any administrative period—90 days.

The regs clarify that it’s calendar days that count. Days matter: If the 91st day is a weekend or holiday, you may permit coverage to begin earlier, but you can’t allow it to begin later. Likewise, coverage may start sooner than the 91st day if you don’t want it to start in the middle of a month or pay period.

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