New Guidance on Employment-Based Orientation Periods

As employers who sponsor group health plans well know, health care reform prevents plans from imposing waiting periods in excess of 90 days for employees who are otherwise eligible to enroll in a plan.  The latest guidance relating to the waiting-period rules addresses the boundaries of “reasonable and bona …

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IRS Requests Input on Full-time Employee Definition

On May 3, the IRS issued a request for comments on the employer mandate (or “pay or play”) and the 90-day waiting period provisions of the health care reform law.  These provisions are effective in 2014, and before issuing guidance on these topics, the agencies are asking for comments. A key definition for …

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