"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."

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"The Notice says the Plan seeking recoupment notifies the recipient plan and the participant of the overpayment. It states the tax consequences and how the overpayment can be transferred back without the participant incurring taxable income. What I do not see is authorization for the recipient plan to just transfer the money back without the participant's consent. Can the recipient plan transfer the funds back solely on the basis of the notice and the Notice? That is, can this be done without liability to the participant?"