TPA Bob Posted October 2, 2017 Share Posted October 2, 2017 We have a participant in a premium only plan who is asking to drop his dependent group coverage due to qualifying for cheaper individual coverage through the State of Oklahoma (Sooner Care). I have looked at our language (Sungard / Corbel/ FIS) post-Affordable Care Act and it appears this is not a change of status and would not be allowed. Any thoughts? Link to comment Share on other sites More sharing options...
Debbie Posted October 3, 2017 Share Posted October 3, 2017 It should qualify as a special enrollment period/qualifying event. Link to comment Share on other sites More sharing options...
mdm09 Posted October 5, 2017 Share Posted October 5, 2017 Assuming Sooner Care is a form of Medicaid (not Exchange coverage), an employer-sponsored plan can (but is not required to) allow an individual who loses Medicaid to enroll in the plan mid-year, but the reverse is not true--the plan cannot allow an individual to drop plan coverage mid-year if he or she enrolls in Medicaid. See Treasury Reg. 1.125-4(f)(5). Link to comment Share on other sites More sharing options...
Peter Gulia Posted October 5, 2017 Share Posted October 5, 2017 If you'd like to read the rule mdm09 refers to, here's a link: https://www.ecfr.gov/cgi-bin/text-idx?SID=2dd0cb953fab89b3f5b297cd598aa3f8&mc=true&node=se26.2.1_1125_64&rgn=div8 Peter Gulia PC Fiduciary Guidance Counsel Philadelphia, Pennsylvania 215-732-1552 Peter@FiduciaryGuidanceCounsel.com Link to comment Share on other sites More sharing options...
jsb Posted October 5, 2017 Share Posted October 5, 2017 Have to disagree with mdm09 on one point. Under 1.125(4)(e), entitlement (enrollment) in Medicaid (or Medicare) would permit a drop of coverage, if the employer's plan permits. If Sooner Care is not the state version of Medicaidl, it is likely an individual plan that would not permit a change in election Link to comment Share on other sites More sharing options...
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