On March 21 the Department of Labor (DOL) issued a proposed rule to implement the 90-day waiting period limitation in the Public Health Service Act, as added by the Patient Protection and Affordable Care Act (PPACA). In addition, the proposal includes amendments to regulations to conform to PPACA provisions already in effect, as well as those that will become effective beginning in 2014.

In September 2012, ABC joined the Employers for Flexibility in Health Care (EFHC) coalition in submitting comments about determining full-time employee status and the application of the 90-day waiting period limitation. The comment letter was submitted in response to notices issued by the Departments of Labor, Health and Human Services, and the Internal Revenue Service (IRS). The letter and additional compliance information is available in the Oct. 5, 2012 Newsline article

Comments are due by May 20 and can be submitted at www.regulations.gov.