Earlier this year, the agencies implementing the Affordable Care Act published a final rule that prohibits health plans and health insurance issuers from applying any waiting period that exceeds 90 days (i.e., the waiting period that must pass before an individual is eligible to receive benefits under a health plan).
Even though, under the ACA, the 90-day waiting period rule took effect for plan years beginning on or after Jan. 1, 2014, many plan sponsors have yet to update their work policies (for example, employee handbooks and collective bargaining agreements) in order to coordinate their provisions with the rule and/or with plan document language that incorporates the rule.