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Health Care Reform: FAQ Part XVI Addresses Insurance Exchange Notice and 90-Day Waiting Period Requirement

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September 2013

The Treasury, the Department of Labor and the Department of Health and Human Services have released new FAQs about the implementation of the Affordable Care Act. The FAQs contain information on who can supply the notice of exchanges, providing that the issuer, a multiemployer plan or third-party administrators may (but are not required to) send the notice on behalf of the employers. Further, the FAQs address issues related to compliance with the 90-day waiting period limitation, providing that plans and issuers can rely on the proposed rules throughout 2014. Final regulations will not be enforced before January 1, 2015. The FAQs also clarify that certain multiemployer plans may rely on substantive eligibility requirements based solely on the passage of time when such requirement is not designed to avoid compliance, but to accommodate a unique operating structure. This clarification is helpful for multiemployer plans which may provide that employees become eligible for coverage after working certain number of hours of covered employment across various contributing employers. 

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