Critical Steps in Preparing for 2015 Open Enrollment Season

By Larry Reynolds

Accurately informing employees of available health benefits, communicating changes to a corporate health program and instructing workers how to choose and change their personal benefits package are critical tasks that employers must accomplish during open enrollment, Mike Sinkeldam, a principal at New York-based consulting firm Mercer LLC said during the Aug. 7 webinar, “Preparing for 2015 Open Enrollment.”

Companies should use open-enrollment season to ensure vital housekeeping chores, such as beneficiary designations and dependent information, are correctly completed and that workers are educated about changes required by the Affordable Care Act (Pub. L. 111-148), Sinkeldam said. The changes should be communicated in a way that is understandable by the typical employee, he said.

Legal compliance requirements also should be communicated, Sinkeldam said. This includes the different notices and reports that are mandated by federal law or by state law, he said.

Employers should remember such legally required communications as a notice that explains to new hires how to use a public health exchange, including relevant information about tax credits and subsidies, said Mercer health principal Babette Madison.

All existing materials should be updated to reflect 2015 requirements, Madison said. This includes health-insurance provisions for full-time employees and changes that are to go into effect, such as waiting periods, and changes in eligibility requirements, she said.

Consolidated Omnibus Budget Reconciliation Act notices should be updated to explain how they may affect enrollment in the exchange marketplace, Madison said.

COBRA gives workers and their families who lose their health benefits the right to choose to continue group health benefits provided by their group health plan for limited periods of time under certain circumstances, such as voluntary or involuntary job loss, reduction in the hours worked, transition between jobs, death, divorce and other life events.

Understanding Summary Changes

Employers should ensure that appropriate changes are reflected in summary plan descriptions and in summary of material modification documents, Madison said.

Employers should consider facilitating delivery and saving costs through electronic delivery of open-season notices.

Employers also must distribute a summary of benefits and coverage, which is in addition to and not in place of the summary plan description, Madison said. The summary of benefits is meant to be an easy-to-read document that employees may use to compare coverage options, she said.

Employers should consider electronically delivering the notice to facilitate its delivery and reduce the associated costs, but employers must ensure government requirements are met, Madison said.

For plans that are governed by the Employee Retirement Income Security Act, it is critical to ensure that the required documents are received by individuals, Madison said. Employers must be able to verify that materials were delivered to individual employees, so posting the material on a company's internal website is not good enough, she said.

Paper copies of the required documents must always be available to employees and beneficiaries on request, and employers should include a notice to employees that explains the significance of the documents being provided, Madison said.

State and Local Requirements

Employers must be aware of local and state requirements, as well as federal requirements, depending on where they are located, Sinkeldam said.

For example, San Francisco and Vermont mandate that employers contribute to health-care coverage or pay a surcharge, he said. Companies in these areas must submit additional reports to verify employee coverage.

Employers should use the open-enrollment time to ensure that all plan documents and forms reflect legal changes relating to same-gender spouses or partners in the wake of the Supreme Court's ruling in United States v. Windsor(U.S., No. 12-307, 6/26/13) that the Defense of Marriage Act (Pub. L. 104-199) violated the constitutional guarantee of equal protection when applied to same-sex couples legally married under state law, Sinkeldam said.

Employers should create an internal website explaining for employees the changes brought about by the ACA, Sinkeldam said. The website should be viewable from technology platforms including tablets and smart phones.

Workers may be given a plastic card to keep in their wallet that they can use to link to a summary of benefits from their cell phone, Sinkeldam said. Other important web links and phone numbers also should be provided to employees.

For workers who may not have home computers or smart phones, explanatory videos covering critical information that is needed during open enrollment may be made available by employers for employees to borrow for review at work during certain designated times, Sinkeldam said. These videos should be available in English and Spanish, depending on workforce demographics, he said.

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