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Amending Plan to Eliminate Annual Open Enrollment Period


Guest laretta
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Guest laretta

The employer is switching from a self-funded plan to a fully insured health plan. Annual open enrollment for the self-funded plan is April 1, but open enrollment for the insured plan does not begin until June 1. The employer does not want to permit anyone to enroll in the self-funded plan on April 1. Can they amend the plan to eliminate the annual open enrollment period? If so, what kind of notice do they need to provide to plan participants?

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Do you contemplate not offering any coverage to EEs for April and May 2008? or is it that the ER does not want to allow any NEW enrollees? Your OP could be read either way, but I think it more likely that the ER is continuing the self-funded coverage to 6/1/2008 and doesn't want any new enrollees between now and then. So I'll answer your question that way.

I think you'd at least need to let enrolled EEs the option to drop coverage effective 4/1/2008, as the last election was an ANNUAL enrollment, not one from 4/1/2007-6/1/2008.

I don't think that you'd need to allow EEs generally to enroll. However, you may want to take a look at HIPAA special enrollment rights. Off the top, I don't think it would pose a problem, but merely suggest that you check.

Make sure the amendment meets the procedure requirements set forth in the plan document.

As far as a notice, I think you merely need to explain that there will be no annual enrollment, but that each current enrollee that does not want coverage beyond March 31, 2008 will need to make an election to that effect no later than March 31, 2008.

John Simmons

johnsimmonslaw@gmail.com

Note to Readers: For you, I'm a stranger posting on a bulletin board. Posts here should not be given the same weight as personalized advice from a professional who knows or can learn all the facts of your situation.

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