Comment on FR Doc # 2013-06454

It would be very helpful to the administration of group health plans if this legislation was amended to state 'first of the month following 90 days'. Many employers have a 90 day waiting period, but depending upon the date an employee is hired, they may have a waiting period beyond 90 days as they wait for the first of the month to arrive. The majority of fully insured insurance carriers do not start benefits on the 91st day - it is first of the month following the 90th day. Amending the legislation to meet what the majority of carriers are doing administratively would be very helpful. Otherwise, insurance carriers will have to determine prorated premium for each day of each month which is unreasonable for the insurance carrier, as well as the employer who will have to determine the employee's pro-rated premium contribution.