That's what I was thinking as well, but how does that mesh with the rule that you can't have waiting periods before eligibility of longer than 90 days? It seems that one rule is contradicting the other ...
The open enrollment period is just for qualifying events, like those who did not enroll when they were first eligible but want to hop on the plan later. The new-hire waiting period of 90 days is for those folks who are first eligible by reason of new hire.
By the way, the new 90 day waiting period is brutal. It is exactly 90 days, not 3 months, and not "FOMF" (First of the Month Following) 90 days. So, if you want all employees in your group to have an effective date of the 1st day of a month to avoid partial month billing problems and potential double coverage with their current plan, you have to give them a waiting period of First of the Month Following 60 days.
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