The DOL recently (June 25, 2014) issued additional regulations regarding an Orientation Period for Employers.
This Orientation Period is meant to provide both employer and employees alike the opportunity to evaluate whether the employment situation is satisfactory for each party. This period can occur prior to the start of the maximum 90-day eligibility (waiting) period for medical benefits.
This length of this Orientation Period is very unique and deserves special attention. The Orientation Period can be one calendar month MINUS one calendar day from the employee’s start date.
For example, if an employee’s start date in an otherwise benefit eligible position is March 3, the last allowable day of the orientation period would be April 2. In this example, the maximum 90-day waiting period would begin on April 3 and the employee must be offered coverage by July 2 in order to comply with the regulations.
Consistent with the Employer Mandate of the PPACA, group health plans and health insurance issuers for plan years beginning on or after January 1, 2015 must comply with these final regulations. For more information please Contact Us and we would be happy to assist you.
