The ACA prohibits waiting periods for employees to no longer than 90 days with a few exceptions.
First, orientation periods are allowed before the 90 day waiting period begins; as long as the orientation is for a valid “employment-based reason.”
Second, if the plan has a minimum cumulative service requirement it cannot exceed 1200 hours.
Employers whose group plans began in 2014 are probably aware of the limitation on waiting periods but don’t forget to update the ERISA plan documents.
The employee handbook must be updated too or disputes could arise potentially exposing the company.
NOW is the time to make sure all your plan documents and handbooks are in order.
Please contact L&A Services for any needs regarding your business’ group benefit plans.