Waiting Periods
A waiting period is the time duration employees must wait before their coverage becomes effective. Under the ACA, the maximum new-hire waiting period is 90 days from the date of full-time employment. However, small employers might be able to add a one-month orientaion period or a cumulative hours requirement prior to the beginning of the waiting period. And companies with variable-hour employees can impose a one-year initial measurement period during which time they determine full- or part-time employee status.
Are part-time employees subject to the same new hire waiting periods as full-time employees?
Employers have discretion in setting waiting periods for part-time employees, and these can differ from those set for full-time employees. However, if a part-time employee is expected to work enough hours to meet the full-time criteria (generally 30 hours per week), the 90-day maximum waiting period would apply. Employers must…
Can an employer extend the waiting period beyond 90 days under special circumstances?
No, an employer cannot extend the waiting period beyond 90 days, regardless of circumstances. The 90-day limit is a strict maximum under the ACA. Any coverage delay beyond this period can result in penalties for non-compliance with the ACA’s employer mandate.
What are the rules for the initial waiting period for variable hour employees?
For variable hour employees, those whose working hours are uncertain, employers can use an initial measurement period to determine the employee’s average hours. This period can be up to 12 months and is used to ascertain if the employee meets the full-time eligibility criteria for health insurance coverage. After this…
How does an orientation period affect the new hire waiting period?
An orientation period is the time an employer may use to evaluate whether an employee’s employment will continue and for the employee to learn about their job. The ACA allows employers to impose an orientation period before the start of the 90-day waiting period for health insurance coverage. However, the…
What is a new hire waiting period for health insurance coverage?
A new hire waiting period is the time an employee must wait before becoming eligible to enroll in the employer-sponsored health insurance plan. This period begins when an employee starts working and continues up to a set time defined by the employer. Under the Affordable Care Act (ACA), the maximum…
What is an orientation period? How is it different from a new-hire waiting period?
By law, the maximum waiting period for a fully-insured small group plan is 90 days from the date of full-time employment. In practice, with many carriers it’s first of the month following 60 days since it’s easier to start on the 1st of the month and the waiting period can’t…