Towers Watson Analyzes ACA Waiting Period Requirements

In "Short Orientation Periods Need Not Count Toward 90-Day Waiting Period for Group Health Plans", Towers Watson reports that:

"The regulators are allowing employers to include up to a one-month employee orientation period followed by up to a 90-day waiting period. The clock starts ticking on the employee’s start date and all calendar days count, including weekends and holidays. Employers could be in compliance with the final regulation on orientation periods while still being in violation of the play-or-pay mandate."

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