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Text of SHRM Comments on Proposed DOL Regs for ACA 90-Day Waiting Period (PDF)
Society for Human Resource Management [SHRM] 
[Opinion] May 22, 2013
"Under current and past practice, employers often adopt a 'first of the month' following 90 days eligibility rule to coincide with employment probationary periods which are designed to help determine whether the employment relationship works for both the employer and the employee. Decreasing a probationary period to two months (and adopting a waiting period that runs to the first of the month following two months of employment) simply to accommodate an accelerated eligibility for health coverage does not make sense from an overall HR perspective, and further would undermine employer attempts to adopt best practices in human resource management."
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