Annual Open Enrollment Period

[Guest jdreed]

Has anybody eliminated the usual annual open enrollment period and allowed changes throughout the year? What were the some of the issues encountered in doing this?

[Lisa Hand]

Elections for 125 plans are required to be done prior to the start of the plan year and changes are only permitted during the plan year if a valid change of status occurs and the participant requests a change within the time period detailed in the plan documents.

So the short answer should be no one has gone to that type of set up since it would result in an out of compliance plan.

[Guest ronc]

A variation of this has been done for the last twos year by the Commonwealth of Virginia employees' medical plan. They call it a floating open enrollment. If an employee has not made a change in his plan during the last 12 months, he may make an election change at any time. A qualified status change can be made at any time, as long as it is within 31-days of the change. They also have a normal annual election for spending accounts and to opt-in or out of premium conversion.

I know they had requested an IRS ruling, but I am not sure if they received one.