Starting in 2014, the Affordable Care Act (ACA) will limit waiting periods for health insurance plans to a maximum of 90 days. The 90 day waiting limit takes effect for plan years beginning on or after January 1, 2014 and will apply to small and large group insurance plans as well as self-funded plans. The important thing to remember is the maximum is exact. The waiting period cannot end on the first of the month after 90 days is up.
If you plan renews on January 1, 2014 or after and you currently have a waiting period longer than 90 days you will need to shorten the waiting period for the 2014 plan year in order to be compliant with ACA regulations.
The regulation applies to all employees that become eligible for coverage after the beginning of the 2014 plan year. Due to this there might be some employees that were hired during the 2013 plan year whose eligibility for coverage could change one the 2014 plan year begins depending on hire date. It is important for you to correctly calculate when 2013 new hires are eligible for health coverage.
The waiting period only applies to eligibility. If an employee is eligible for health insurance after 90 days but doesn’t join the group the employer is still in compliance.
If you have any questions about the 90 day waiting period please do not hesitate to contact our office.