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If an employee has not yet satisfied a plan’s generally applicable waiting period, does the NMSN meet the ERISA definition of a QMCSO?

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If an employee has not yet satisfied a plan’s generally applicable waiting period, does the NMSN meet the ERISA definition of a QMCSO?

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Yes. Because an employee who has not yet satisfied a plan’s generally applicable waiting period (such as requiring that person to be employed for a certain number of days or to work a certain number of hours before being eligible for medical benefits) is still a participant in the plan, the NMSN is deemed a QMCSO by ERISA standards.

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