Minor Employee Insurance Offer

A minor (17) qualifies for medical benefits under ACA (just a hair over 30 hours) during open enrollment. Wont turn 18 until April. Can we legally offer them their own benefits even though they are not yet 18? Or, do we have to wait to offer until they turn 18 in April? They work in a state where the # of hours worked is not an issue (they earned the minimum hours all within the labor laws). I worry we will be out of compliance with ACA if we don't offer it during open enrollment since they are flagged but have also never offered benefits directly to a minor before.

Does anything in this health plan’s governing documents make an otherwise eligible employee not covered because she is a minor or has not attained a specified age?

BenefitsLink neighbors often say, Read The Fabulous Document. Because ERISA § 404(a)(1)(D) calls a fiduciary to administer an employee-benefit plan according to the plan’s governing documents, RTFD can be a useful work method for a group health plan too, perhaps even more so than for a retirement plan.

This is not advice to anyone.