Believe it or not, the open enrollment period for calendar-year employee benefit plans is just around the corner. But fear not! This year's open enrollment period likely will be much easier to navigate than last year's because several of the healthcare reform-related notice requirements of last year need not be repeated this year. Below is a checklist of notices employers should begin developing in preparation for the 2012 plan year open enrollment period:
- Medicare Part D Notice (as we mentioned in a prior edition of the Health Law Update this notice must now be disseminated prior to October 15th);
- CHIPRA Notice Regarding Special Enrollment Rights;
- Women's Health and Cancer Rights Act Notice; and
- Wellness Programs "Alternative Standards" Notice.
In addition, employers sponsoring group health plans that will be maintaining their grandfathered health plan status for the 2012 plan year should disseminate a Grandfathered Health Plan Status Notice so that plan participants will be reminded that certain aspects of healthcare reform do not apply to the grandfathered plan.
Finally, employers sponsoring group health plans that will be losing their grandfathered health plan status for the 2012 plan year will need to disseminate the following notices:
- Extension of Dependent Coverage Notice (to put employees on notice that their dependent children who have another offer of employer-sponsored coverage are now eligible to participate in the employer's health plan); and
- Patient Protection Notice (to put employees on notice that a health plan that has lost its grandfathered status will now need to comply with the patient protection requirements of healthcare reform).