COMPLIANCE UPDATE: OPEN ENROLLMENT 2020 BENEFIT NOTICES

New Compliance Update.

Employers that sponsor group health plans should provide certain benefit notices in connection with their plans’ open enrollment periods. Some of these notices must be provided at open enrollment time, such as the summary of benefits and coverage (SBC).

Other notices, such as the Women’s Health and Cancer Rights Act (WHCRA) notice, must be distributed annually. Although these annual notices may be provided at different times throughout the year, employers often choose to include them in their open enrollment materials for administrative convenience.

In addition, employers should review their open enrollment materials to confirm that they accurately reflect the terms and cost of coverage. In general, any plan design changes for 2020 should be communicated to plan participants either through an updated summary plan description (SPD) or a summary of material modifications (SMM).

This Compliance Overview includes a chart that summarizes the benefit notices employers should provide at open enrollment.

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