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Final ACA Rule Permits One-Month Orientation Period
HighRoads 
[Guidance Overview] June 25, 2014
"[In] some cases the employer may not be able to utilize fully both the one-month orientation period and 90-day waiting period without potentially becoming subject to an assessable payment under Code section 4980H, if those periods would cause the employer to not offer coverage by the first day of the fourth full calendar month of employment.... The departments anticipate that the cost impact of the rules will be limited as it is anticipated that the inclusion of an orientation period will not result in most employees facing a full additional month between being hired and obtaining coverage."
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