Open Enrollment Is Coming – Get Your Notices Ready

Open Enrollment Is Coming – Get Your Notices Ready

Businesses that offer group health coverage must provide plan participants with a wide range of notices informing them about specific rights, options, and available resources.  Who must get what notice and when may vary, but according to federal guidance, open enrollment is the time to distribute many required health plan disclosures. Our Employee Benefits Consultants are also always happy to review your plan’s notices individually and make sure that you are sending out the right documents to the right people at the right time!

The annual notices that should be in each open enrollment packet for every plan include:

Summary of Benefits and Coverage and Uniform Glossary—These documents provide an overview of each plan option your company offers and definitions of common health insurance terms.  Kistler Tiffany Benefits will help make sure that you have an appropriate SBC for each plan option offered to employees, and the content will come from either your health insurer or third-party administrator.  In most cases, you can provide one streamlined document if you offer consumer-directed coverage with an account-based plan option, but some health reimbursement arrangements (HRAs) will require two separate documents.

Women’s Health and Cancer Rights Act Notice—This notice provides enrollees with information about a federal law that provides protections to patients who have breast reconstructive surgery in connection with a mastectomy.  The Department of Labor has made a template available for employers to use to produce their notices.

Children’s Health Insurance Program Premium Assistance (CHIPRA) Notice—This notice informs plan participants about the potential availability of premium assistance programs for Medicaid and Children’s Health Insurance Program participants.  There is a federal model notice for employers to use, and it can be modified just to include the states where your employees live.

Some notices only need to be distributed at open enrollment if your health plan includes specific components:

Grandfathered Plan Notice—If your company offers any coverage option that has “grandfathered status” according to the Patient Protection and Affordable Care Act (ACA), then you must provide a grandfathered plan notice that follows the federal template.

Wellness Program Disclosures — If your health benefits package includes a wellness program, two different notice requirements could apply.  All companies that offer a wellness program that requires participants to meet a standard based on a health factor before they get a reward need to provide enrollees with an annual disclosure that complies with federal guidance.  Also, any employer wellness programs that ask employees about their medical conditions or asks employees to take medical examinations (such as tests to detect high blood pressure, high cholesterol or diabetes) must provide notice about how employee medical information is kept confidential.  There is a federal template available for this notice too.

The safest way to deliver these notices is by hand (such as in an enrollment packet) or via U.S. mail to the employee’s most current address.  The federal rules allow for electronic distribution, but only if a business meets specific requirements.  Unfortunately, the electronic disclosure rules for most notices do not reflect current technology, and they are not appropriate for many workforces.  Often employees need to have direct access to a company-provided personal computer or exhaustive electronic consent procedures apply.  The federal electronic disclosure rules are also tricky for specific demographic groups and become very difficult if you have COBRA beneficiaries, children covered under child support orders, or retirees on your group plan and in other cases.

If you need any assistance compiling or distributing your plan’s annual notices, please reach out to your Kistler Tiffany Consultant for support.

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