How do I enter different waiting periods for different lines of coverage or classes of employees?

To enter different waiting period information for different component benefits, select the button next to "The eligibility requirements for this benefit are different and I need to enter them," which appears under the "Eligibility" section on the Benefit Component Information page.

To enter different waiting period information for different classes of employees, one way to address this is to create separate plans (with different plan numbers) for the different classes.

Another option is to have one plan, but distribute multiple Wrap SPDs (e.g., one for full-time employees and another for part-time employees) so that employees see only the waiting period and other benefit information that applies to them. In such cases, ERISA requires that each SPD clearly identify on the first page of the text the class of participants and beneficiaries for which it has been prepared and the plan's coverage of other classes. You may wish to use the following sample language:

"This SPD has been prepared especially for the [describe class of employees—e.g., hourly employees, workers at the New York Plant, salesmen, employees hired before 2010, etc.]. The Plan also covers [list all other classes of employees covered by the Plan]."

You can utilize the "Duplicate Employer" to enter the different eligibility requirements for each class. 

If you are choosing to generate one Wrap Plan Document with two Wrap SPDs, for example, you would first enter all of the welfare benefit plan information, which includes both waiting periods (you can do this, for instance, by creating two different benefit options: Medical Plan – Managers; Medical Plan – Employees). Once this document is created, look for the "duplicate employer" function that appears next to the list of employers in Wrap360. This will then create a duplicate document where you can go in and change the title of the document for employees, and delete any benefits that do not apply to the group.  

Alternatively, you can specify that the eligibility requirements are contained in the benefit booklets, certificates, provider contracts and benefit descriptions, or you can customize the documents in Microsoft Word.

 What is a waiting period? Are there any limits on how long a waiting period can last?

A waiting period is the period of time that must pass before coverage for an employee or dependent who is "otherwise eligible" to enroll under the terms of a group health plan can become effective. Being "otherwise eligible" for coverage means having met the plan's eligibility conditions (such as, for example, satisfying a reasonable and bona fide employment-based orientation period).

The Affordable Care Act prohibits group health plans from applying any waiting period that exceeds 90 days. All calendar days are counted beginning on the first day of the waiting period, including weekends and holidays. (A plan that imposes a 90-day waiting period may, for administrative convenience, choose to permit coverage to become effective earlier than the 91st day if the 91st day is a weekend or holiday.)

Therefore, before the waiting period begins, an employer can require employees, as a condition for eligibility for coverage under a plan, to complete a reasonable and bona fide employment-based orientation period. In order to be a permissible eligibility condition under the law (rather than a condition designed to avoid compliance with the 90-day waiting period limit), the reasonable and bona fide employment-based orientation period must not exceed one month, and the maximum 90-day waiting period must begin on the first day after the orientation period.

Effect on Employer Shared Responsibility: Employers with at least 50 full-time employees (including full-time equivalent employees) should review the final regulations regarding employment-based orientation periods and the ACA's 90-day waiting period limit to determine their impact on the "Pay or Play" guidelines.

Please Note: Wrap360 and its employees and officers are not permitted to offer legal advice. These FAQs are provided for general information purposes only. As the answers to specific questions may vary based on federal or state law, as well as on company documents for the issues in question, it would be prudent to consult knowledgeable benefits counsel for individualized guidance.