Effective for the plan year beginning on or after Jan 1, 2014 the new federal maximum 90-day waiting period limit applies to all group health plans, fully insured and self-funded, grandfathered and non-grandfathered. (States may mandate shorter waiting periods.)
Compliant waiting periods include:
- No waiting period
- Date of Event: 1 to 90 calendar days; 1 or 2 months
- First of Month: Following the event, such as date of hire, 1 or 2 months or 1 to 60 calendar days.
We anticipate most employers declaring the eligibility to be ‘first of the month following…’, to minimize (if not eliminate) partial billing, with wording ‘not to exceed 90 days’.