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Orientation Period Final Regs Address Employer Mandate
Practical Law Company Link to more items from this source
[Guidance Overview]
June 24, 2014
"In response to commenters' requests, the Departments address how the 90-day period rules interact with health care reform's employer mandate ... In this context, the Departments note that for a full-time employee who is hired by a large employer on January 6, a plan may offer coverage on May 1 and comply with both the waiting period rules and the employer mandate. However, if the employee is hired on January 6 and health coverage begins on May 6 (that is, one month plus 90 days after the date of hire), the employer will comply with the waiting period requirements but may be subject to an employer mandate penalty."

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