Later (or "after") acquired dependents

[Guest J D DeBacker]

Under HIPAA's later-acquired dependent rules, a plan must offer a special enrollment period if the plan offers dependent coverage and a participant "gains" a dependent. Anyone have any thoughts/experience where a multiemployer plan "used to" restrict retiree's dependent's coverage to spouses who were married to the retiree for at least one year prior to retirement (much like a pension J&S rule). I don't think that the plan can continue this practice, and if it offers retiree dependent coverage, must eliminate the "one year of marriage prior to retirement" rule. Any contrary thoughts? Thanks!