The DOL, IRS and HHS have issued final regulations clarifying the maximum length of an employee orientation period in light of the 90-day waiting period limitation ErisaALERT 2012-13 under the Affordable Care Act (ACA). To guard against potential subterfuges for the passage of time, final regulations provide that one month is the maximum allowed length of […]
90 day waiting period, ACA, orientation periodErisaALERT© The IRS recently issued Notices 2012-58 and 2012-59. Notice 2012-58 addresses the determination of full-time employee status for purposes of shared responsibility. Notice 2012-59 addresses the 90 day waiting period requirements. This Alert summarizes important points in each notice and provides a to-do list for plan sponsors. Notice 2012-58 will be of particular interest […]
2012 archive, 90 day waiting period, ACA, DOL Technical Release, ERISA, Notice 2012-58, Notice 2012-59(c) 2015 Erisa Diagnostics - We focus on benefits, so you can focus on business