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For employers navigating the complexities of the Affordable Care Act (ACA), understanding the permissible health plan waiting periods is important. The ACA sets specific guidelines that employers must follow to ensure their health plans comply, particularly when it involves the timing of employee enrollment.

What are Health Plan Waiting Periods? A health plan waiting period is the length of time that must pass before coverage for an employee or dependent who is otherwise eligible to enroll under the terms of a group health plan can become effective. Under the ACA, this period cannot exceed 90 days. Being otherwise eligible to enroll in a plan means having met the plan's substantive eligibility conditions (such as, for example, being in an eligible job classification, achieving job-related licensure requirements specified in the plan's terms, or satisfying a reasonable and bona fide employment-based orientation period). This means that once an employee becomes eligible the health plan must start providing coverage no later than 90 days from that eligibility date.

ACA Compliance The maximum 90-day waiting period applies to anyone who is eligible for the plan. Importantly, the day the employee is deemed eligible is not included in the 90-day count; the count starts the following day. For compliance, all calendar days are counted, including weekends and holidays, which means employers must carefully calculate the timing to avoid penalties.

Exemptions and Special Considerations It’s important to note that the ACA does allow for what is termed an "orientation period." Employers may use an orientation period of up to one month before the start of the 90-day waiting period. This means the total duration from an employee’s start date to the commencement of coverage may potentially be up to four months under specific circumstances. An orientation period is the that an employer and employee will evaluate whether the employment situation is satisfactory for each party, and standard orientation and training processes will begin. For any period longer than one month that precedes a waiting period, the 90-day waiting period rule applies.

Why Compliance Matters Ensuring compliance with ACA waiting period regulations is not just about avoiding penalties. It also plays a significant role in employee satisfaction and retention. Employees value health benefits highly, and delays in coverage can lead to dissatisfaction and even turnover. Moreover, non-compliance can result in substantial penalties which can impact an organization financially.

Best Practices for Employers

• Review Eligibility Criteria: Clearly define and communicate who is eligible for coverage and when the coverage begins. Understanding the specifics of your workforce and their eligibility status is necessary.
• Monitor Timing: Keep a strict timeline from the date of hire to the commencement of coverage, ensuring it does not exceed the allowed waiting period.
• Communicate Clearly: Make sure employees understand the waiting period and what it means for their health coverage. Clear communication can prevent misunderstandings and ensure smoother onboarding.
• Stay Informed: Healthcare regulations can evolve, so it’s essential for HR professionals to stay informed about any changes in the law that might affect their health plan offerings.

Proper management of health plan waiting periods is a critical component of ACA compliance, helping to protect both the employer and its employees.

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