New DOL FAQ for Exchange Notice and 90-day Waiting Period Limitation Provisions

Posted September 13, 2013 Company News

The DOL issued additional guidance on September 4, 2013, in the form of FAQs, that addresses two specific provisions of the Affordable Care Act — the Exchange Notice requirement and the 90-day Waiting Period Limitation.

Highlights of the new FAQs:

Employers with union employees enrolled in a multiemployer plan will be pleased to hear that the employer’s obligation to distribute the Notice of Coverage Options (Exchange Notice) will be satisfied if the multiemployer plan distributes the notice on its behalf.

The Departments have announced that plan and issuers can rely on guidance provided back in March 2013 for the waiting period limitation at least through 2014. If final regulations are found to be more restrictive than the proposed regulations they will not be effective prior to January 1, 2015.



Please note that the information contained in this document is designed to provide authoritative and accurate information, in regard to the subject matter covered. However, it is not provided as legal or tax advice and no representation is made as to the sufficiency for your specific company’s needs. This document should be reviewed by your legal counsel or tax consultant before use.

Additionally, the messages and content within the Pittsburgh Health Care Reform group do not reflect the advisory services of Henderson Brothers, Inc.


Contributing EXPERT: Shari Herrle

To download the PDF version of this EXPERT UPDATE, please click on the link below: