Comment on FR Doc # 2013-06454

With regards to Paragraph D, write regulations that relfect the law's intent - 90 days, not "first of the month after 60 days". Insurance always takes effect on the first of the month, so a true 90 day waiting period limit means that employers can only comply by setting a "first of month after 60 days" probationary period. The intent of the law was for a 90 day wait to be the max, not a 60 day wait. So let's follow the actual intent of the law and allow the full 90 days by stating that coverage will begin on the first of the month after 90 days, or by counting in months as suggested. Otherwise, we are truly ignoring the main intent of the law and we should honestly state that we are making "first of the month after 60 days" the true waiting period limit.