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Tell Me it’s Not True! Annual Open Enrollment Approaches for Most

August 27, 2024 (4 min read)

Open enrollment, which often occurs in October or November for calendar year plans, is a time when employees and other eligible individuals can enroll in or make changes to their employer-based health insurance and fringe benefit options. The term has sole reference to health insurance because there is no equivalent in life, property, and casualty insurance. Open enrollment also applies to Medicare, Medicare Advantage Plans, and Medicare Part D prescription drug plans. An individual will only have other opportunities to enroll or to make changes in health coverage under specific circumstances, like HIPAA special enrollment. It’s a busy time for human resources departments and their counsel, as they plan participant communications and their delivery.

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  • The 2025 Required Annual Benefit Notices to Employees
    Learn more about the participant notices employers must provide annually, like the Medicare Part D, CHIP, and WHCRA notices. All three can be satisfied together by timing their distribution to meet the October 15 Notice of Creditable Coverage deadline. Multiple other notices are not required to be distributed annually—although employers should consider including some of those additional notices with the required annual notice materials.
  • Open Enrollment Notices Checklist (Health and Welfare Plans) Reference this checklist to identify participant and beneficiary disclosures that ERISA, the Internal Revenue Code, HIPAA, the Affordable Care Act, and other laws require health and welfare plans to provide annually where compliance is satisfied by providing employee disclosures at initial plan eligibility and with the employer's annual open enrollment materials.
  • HIPAA Special Enrollment Rights
    Remember the special enrollment rules. HIPAA amended ERISA to require employer plan sponsors to allow employees to enroll themselves or their eligible dependents in group health plans upon the occurrence of certain specified events (i.e., outside of the sponsor's open enrollment period).

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