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TPA Bob
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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?

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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).

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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

 

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