Comment on FR Doc # 2013-06454

Given that the super majority of current insurance contracts are based on start dates and end dates using the first and last date of the month it is important to provide a practical method for employers to comply with the 90 day rule. If not you end up with an accounting problem prorating premiums, employee contributions, and COBRA costs. I would suggest at minimum a safe harbor provision for plans that use the first of the month after 60 days as the start date. This would comply with all possible dates during the calendar year except for June 2nd and November 2nd since they are followed by back to back 31 day months. Without this type of adjustment employers would go from 12 entry points a year to 365. This combined with the measurement periods for variable hour employees will cause many companies to drop medical coverage simply because the cost of compliance is too great.