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U.S. Chamber of Commerce Comment Letter to EBSA on 90-Day Waiting Period Limitation Proposed Rule (PDF)
U.S. Chamber of Commerce Link to more items from this source
[Opinion]
Apr. 27, 2014

"We urge the Departments to clarify the interplay between these two requirements in instances where employees are not known to be full-time employees, given the regulatory framework for determining the full-time employee status of variable-hour, part-time, and seasonal employees who are not reasonably expected or hired to work full-time. The Chamber asks that the Departments clarify that the 90-day waiting period limitation does not require employers to provide minimum essential coverage effective after 90 days of employment to those employees who have not (or have not yet been determined to have ) met full-time employee status, should that be an eligibility requirement."

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