Comment on FR Doc # 2013-06454

I suggest changing from a 90 day wait to 3 months. Everyone always assume they are the same but they are not. 90 days, literally means 90 days. Problems occur when months have more or less than 30 days. Employers miscount the 90 day period which results in enrollments requested too early, or worse, too late. First of the month following 3 months is much easier for employers and employees to calculate when they are to be effective, thus reducing enrollment problems. Examples assuming first of the month effective date after 90 days vs 3 months. Date of hire counts as the first day. Hire date January 1 90 day wait - Effective date is April 1 3 month wait - Effective date is April 1 (no problem exists) Hire date of February 1 90 day wait - Effective date is June 1 3 month wait - Effective date is May 1 (because february is a short month, the actual 90 days does not occur until May 2. Therefore, the 90 day wait won't be effective until first of the following month.) Hire date of March 3 90 day wait - effective date June 1 3 month wait - effective date july 1 (Even though the employee was hired after the first of the month, the 90 day wait was reached on June 1 because March and May both of 31 days, and april has 30 Most employers would think the effective date would be the next month. If the application is not submitted until sometime in the month of July, the 30 day open enrollment period would have ended on July 1and carriers could decline the application since it was not submitted timely) I know it isn't a huge difference but the 3 month versus 90 days results is less problems determining the correct effective dates for employers.