Restrictions on Status Changes / Annual Enrollment

[Guest GmcyWT]

Are there any issues with being more restrictive regarding status changes and/or annual enrollment for a particular category or class of participants in a group health plan (self-funded with stop loss)?

Health plan has a variety of participants -- active employees, retired employees, COBRA participants, etc. Say that active employees and COBRA participants are permitted to make annual enrollment changes and to add new dependents based on qualified status changes/events (birth, marriage, etc.).

Are there any issues with being more restrictive with respect to the retired employees (e.g., providing retiree medical coverage to the retired employee and any eligible dependents (determined as of the date of retirement), but excluding coverage for a new spouse or other person who becomes a dependent after retirement)?

What if the employer provides certain former employees with an extension of medical coverage prior to COBRA (e.g., one year of continued coverage for every year of service). Can the employer provide that those "extended coverage" participants are not permitted to make status changes or annual enrollment changes, until they eventually start their COBRA coverage (at which point they would be permitted to add new dependents, make annual enrollment changes, etc.)?

Thanks in advance for any thoughts.