Human Resources
Legislative Thought Leadership

The Wait Is Over—Government Issues Final Regulations on 90-Day Waiting Period


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Under the Patient Protection and Affordable Care Act (Affordable Care Act), grandfathered and non-grandfathered group health plans and health insurance issuers may not impose any waiting period that exceeds 90 days for plan years beginning after December 31, 2013. The three departments charged with administering the Affordable Care Act—Treasury, Labor, and Health and Human Services— published final regulations implementing the 90-day waiting period on February 24, 2014.

The final regulations contain rules that provide guidance on the employer mandate penalty, permit the use of an orientation period for full-time employees (FTEs) before the waiting period commences, and provide for the phase-out of HIPAA certificates of creditable coverage. This Aon Hewitt bulletin describes the changes made in the final regulations as well as the impact of the final and proposed regulations on employer group health plans.

Download The Wait Is Over—Government Issues Final Regulations on 90-Day Waiting Period