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April 01, 2014 | Leave a Comment
I’m thrilled by the participation in our “Review, Refresh, and Regroup” on the Affordable Care Act webinars last week. All in all, there were about 200 attendees over the two presentations! Thank you for your time and attention.
Many of the follow up questions revolved around a few newer concepts that I introduced in my slides. One in particular was the “Orientation Period” that was discussed. In effect, this may allow you to extend the time that a new hire must wait to enroll in health coverage.
On February 20th, 2 new rules were released by the DOL, HHS and IRS regarding the 90-day waiting period limit. The rules provide that your eligibility period can include a 90-day waiting period and up to a 1 month “Orientation Period”. The Orientation period can be a time in which an employee must obtain a job-related licensure or it may simply be a time to satisfy a “reasonable and bona fide employment-based orientation period”. Per the departments, this “reasonable and bona fide employment-based orientation period” meets the requirements if it provides a period of time in which the employer and employee can evaluate whether the employment situation is satisfactory for each party, and standard orientation and training has begun. Sounds pretty easy to meet these requirements! Please click here to learn more.
Another question that I had a few times was, “You made reference to a Formal Wellness Plan. What exactly does that mean?” There are a few rules that your plan must follow in order to ensure that the differences in premium that you charge your employees are not considered discriminatory.
The plan must have a reasonable design, must offer multiple opportunities to participate and must have a reward that is consistent with the effort required to participate. There must be a reasonable alternative offered and the participants must receive an appropriate amount of notice before the plan opportunities are no longer available. Please click here to read more about this.
What I hope that most of you got out of my presentation is that you absolutely continue to have a knowledgeable partner who can help you work through, what I have calculated to be, about 27,429 pages of law, regulations, examples, guidance and opinions. Cornerstone is here for you to answer questions, offer suggestions, and assist with calculations, reporting and communication.