Cafeteria Plan to Pay Exchange Premium

[Oh so SIMPLE]

If a company has fewer than 25 employees and includes in its cafeteria plan the option for payment of premiums to pay for State Exchange purchased health insurance beginning 1/1/2014, may the cafeteria plan impose minimum service and entry date requirements that would put cafeteria plan eligibility beyond 90 days after employee begins working 30 or more hours a week?

Generally, Obamacare requires health plans not require more than 90 days. So the question is whether a cafeteria plan that allows for payment of State Exchange purchased insurance, whether such a cafeteria plan is a 'group health plan' or merely a mechanism for paying premiums. If just a payment mechanism, the 90 day requirement should not apply. If such a cafeteria plan is itself a 'group health plan', then the 90 day rule would apply.