On Feb. 20, the Internal Revenue Service (IRS), Dept. of Labor (DOL) and Dept. of Health and Human Services (HHS) jointly released two sets of regulations — one final, and one proposed — on the 90-day waiting period limit under the Affordable Care Act (ACA).
Both sets of rules are effective for plan years beginning on or after Jan. 1, 2015. However, the March 2013 proposed regulations were effective for plan years beginning on or after Jan. 1, 2014, so for 2014 a plan will be in compliance if it complies with either the 2013 proposed or the 2014 final regulations.