The fall season is a time of change, especially for HR and benefit professionals.
Fall brings more than just daylight savings time change or the colors of the trees, it brings open enrollment. Each year HR and benefit professionals must provide employees with options for the next plan year. The list of activities for this season should include the following:
Summary of Benefits & Coverage (SBC). A new requirement for this year is the SBC, under the Affordable Care Act (ACA). You must provide an SBC to all applicants and enrollees for all group health plans, except for those that are excepted benefits under HIPAA (e.g., stand-alone dental, vision, most Health FSAs). This requirement is effective for open enrollment periods that start on or after September 23, 2012.
Grandfathered Plan Notices. Employers must send this notice to all participants if the plan is to maintain its grandfathered status. Grandfathered plans do not have to comply with some of the rules related to the ACA. However, they must comply with other rules, like annual and lifetime limits, dependent coverage up to age 26, rescission and limits on preexisting condition exclusions (PCEs).
Patient Protection Disclosures. Also under the ACA, employers must notify participants of their right to designate any primary care provider who participates in the network. If the plan allows for the designation of a primary care provider for a child or for an obstetric/gynecological care provider, these must also be included in the notice.
Medicare Part D Creditable Coverage Notices. All employer-sponsored plans that offer a prescription drug benefit must annually notify participants as to whether their coverage is creditable or non-creditable. This year the deadline to mail these notices was October 15. The Medicare Part D annual enrollment period is October 15 through December 7. This will require notices to go out prior to most plans being finalized. Any changes to creditable status once a plan is finalized will require another round of notices to be sent.
COBRA Qualified Beneficiary Communications. COBRA regulations require many notices; one of those is the Open Enrollment Notification. This is a requirement that states employers provide the same rights to COBRA Continuees during an open enrollment period that are offered to active employees. This notice is required even if the only change is the COBRA rates. The open enrollment packet must be sent to:
- Possible Electees (individuals in their 60-day election period)
- Electees (individuals who have elected but have not yet paid)
- Continuees (individuals who have elected and paid)
Health FSAs. Health FSAs are another open enrollment challenge. If the Health FSA is a HIPAA-excepted benefit and the employer need only offer COBRA when the FSA account is underspent, then the COBRA obligation ends at the end of the first plan year. However, if the employer somehow does not qualify for the limited obligation, the employer must provide the opportunity to elect Health FSA coverage for the next plan year. Also, if the COBRA period is also covered by USERRA because of a military leave of absence, the employer must continue to offer the Health FSA.
For plan years starting in 2013, Health FSAs have a $2,500 salary reduction contribution limit. This limit is indexed for inflation. Plan documents and Summary Plan Descriptions must be revised.
Infinisource Can Help
Infinisource can send and process open enrollment for your COBRA population. We can manage enrollment and answer questions, providing information to employers and carriers through eligibility reports. The open enrollment packet can look just like you want it. In addition, Infinisource can also help with the other notices listed above. We can also provide great open enrollment tools if we administer your Health FSA or Health Reimbursement Arrangement.
It’s as simple as watching a leaf fall to the ground. Contact a Customer Response Specialist at 866-320-3040 to get started. Don’t let your open enrollment pile up like the leaves.
What are your open enrollment plans? Have you planned any big changes for 2013? What is your biggest open enrollment concern or challenge?