Thursday, September 2, 2010

Adult children enrollment opportunity notice requirement

Under the Patient Protection and Affordable Care Act (PPACA), adult children up to age 26 can be covered under their parents’ health plan for plan benefit years beginning on or after September 23, 2010.

As part of the interim final rule, plans are required to provide newly eligible children a special 30-day enrollment period, including written notice of the opportunity to enroll in the plan.

The plan must provide the notice and enrollment opportunity by the first day of the first plan year that begins on or after September 23, 2010.

Notice of this enrollment right may be provided to an employee on behalf of the employee’s child and can be provided with other enrollment materials. Below is model notice language that employers should provide to employees in conjunction with their open enrollment period.

Model Notice

Individuals whose coverage ended, or who were denied coverage (or were not eligible for coverage), because the availability of dependent coverage of children ended before attainment of age 26 are eligible to enroll in [insert name of group health plan or health insurance coverage]. Individuals may request enrollment for such children for 30 days from the date of notice. Enrollment will be effective retroactively to [insert date that is the first day of the first plan year beginning on or after September 23, 2010]. For more information contact the [insert plan administrator or issuer] at [insert contact information].

Grandfathered Plans
Grandfathered plans may exclude otherwise eligible adult children under age 26 until 2014 if they are eligible for insurance coverage through their employer or, if married, through their spouse’s employer. This stipulation should be added to the notice provided by grandfathered plans.

For your convenience, we have created a template Enrollment Opportunity Notice to address both the lifetime dollar limit and adult children enrollment opportunities. You can use this notice to communicate these opportunities to employees.

For more information, please refer to the previous post: Interim final rule released on provision extending dependent coverage to age 26.

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