To prepare for open enrollment, group health plan sponsors should be aware of the legal changes affecting the design and administration of their plans for plan years beginning on or after Jan. 1, 2017. Employers should review their plan documents to confirm that they include these required changes.
In addition, any changes to a health plan’s benefits for the 2017 plan year should be communicated to plan participants through an updated summary plan description (SPD) or a summary of material modifications (SMM).
Health plan sponsors should also confirm that their open enrollment materials contain certain required participant notices, when applicable—for example, the summary of benefits and coverage (SBC). There are also some participant notices that must be provided annually or upon initial enrollment. To minimize cost and streamline administration, employers should consider including these notices in their open enrollment materials.
Highlights
PLAN DESIGN ISSUES
• Confirm your plan’s out-of-pocket maximum complies with the ACA’s limits for 2017.
• For HDHPs, confirm that the plan’s deductible and out-of-pocket maximum comply with the 2017 limits.
• For wellness programs that include HRAs, review compliance with the new EEOC rules.
NOTICES TO INCLUDE
• Annual CHIP notice
• Medicare Part D creditable coverage notice
• Notice of grandfathered status (if applicable)
• Annual notice regarding coverage requirements for mastectomy related benefits (WHCRA notice)