Under the ACA, effective for plan years beginning on or after January 1, 2014, a group health plan may not have a waiting period that exceeds 90 days. The ACA’s statutory language raised many questions regarding how this 90-day limit on waiting periods should be measured. Notice 2012-17 continues to leave many of those questions unanswered, but it confirms that future regulations will incorporate the existing regulatory definition of “waiting period.”
Under those existing regulations, a waiting period is defined as the period 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. This suggests that other eligibility conditions that are not based solely on the lapse of a time period (such as full-time vs. part-time status, or bona fide job categories) will still be permitted. In fact, the FAQs specifically state that nothing in the waiting period rules will require employers to offer coverage to part-time employees or to any other specific category of employees.
The Departments of Labor, Health and Human Services, and Treasury intend to issue guidance addressing the coordination of the employer shared responsibility provision with the 90-day waiting period limitation. That guidance is expected to provide that, at least for the first three months following an employee’s date of hire, an employer will not be subject to a shared responsibility tax penalty merely because it fails to offer coverage to the employee during the waiting period.
Feedback From Our Happy Customers
I wanted to take a moment and tell you how absolutely thrilled I am to have Innovative Benefit Planning as my broker. We moved over roughly a month ago and I have never received service like I have since making the transition. With so many employers being challenged with COVID19 and us making the move right in the middle, it could not have been more seamless. Everything was set up to exceed all expectations and it continues. Innovative Benefit Planning has taken the worry and stress away. It was truly the best decision for Title Alliance and I look forward to a long and productive partnership.
The Innovative team is well respected at AFS. My staff and I feel they are an extension of our HR team! Since implementation, they have always remained committed to assisting AFS with all of its healthcare needs; in fact, it doesn’t matter what time of day, they always respond in a timely manner.
Each year they come up with fresh material so our employee’s interest is always peaked. A few years ago, Innovative provided us with documentation to show that moving from a fully insured program to self-insured would be more cost effective for AFS, and it has been! Innovative has truly made our jobs easier so we can focus on other tasks.
As an HR professional, Innovative makes my job easier and benefits administration much less overwhelming than it would otherwise be.
They are truly a partner with me to make sure our team members have the best benefits and service around their benefits that we can offer. Innovative’s team is responsive, professional and resourceful. (They are at the forefront of knowledge in many areas, including ACA reporting and compliance, which can get highly complicated.)
As a client for the last 4 years, we love working with our Innovative Benefit Planning team because of their service model, scope , depth and quality of expertise in handling our benefits and renewals.
Their level of commitment just keeps getting better each year. They have more than met our expectations on renewal negotiations, response time, assistance with ongoing plans, open enrollment material, meetings, support, bill auditing, and wellness programs.
Since our partnership with Innovative Benefit Planning in 2017, it has been a seamless one. Innovative always provide options, suggestions and recommendations when it comes to our benefits renewal.
Innovative is always present even when open enrollment ends, their year round communication reminds me that I can always reach out for help at any time. Their professionalism is the utmost one can expect. My account representative Jenni is wonderful, courteous, knowledgeable and very helpful.
We have been dealing with Innovative Benefit Planning for many, many years. They have given us nothing but exceptional service.
We can pick up the phone or email them and they always resolve our questions and take care of our employees insurance issues in a very timely manner. They negotiate our insurance rates every year and have managed to reduce the increase every year. Every account manager we’ve had throughout the years have been great to work with.
I have been working with Innovative Benefit Planning for over six years. Previous to Innovative, I had used the same broker for about 25 years. I was used to doing everything myself during open enrollment with my previous broker.
When Innovative came on board, I was pleasantly surprised how “on top” of things they were. I never have to call them and bother them about getting rates to me for open enrollment, as they are in touch with our carriers on a regular basis, and they get me my information for open enrollment as soon as they receive it from the carriers.