Annual Notice Requirements
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The document outlines the requirements for employers regarding notices related to Medicare Part D, creditable coverage, and other disclosures affecting group health plans, particularly emphasizing the need for annual notifications. It specifies deadlines for sending notifications to employees, with particular focus on new hires and COBRA continuants, and describes conditions under which additional notices must be sent when there are changes to coverage. It also highlights the obligation to inform participants of their rights under the Affordable Care Act related to primary care provider designations and grandfathered plan statuses.
Annual Notice Requirements
- 1. MODEL EXCHANGE NOTICE MEDICARE PART D CREDITABLE COVERAGE PATIENT PROTECTION DISCLOSURES GRANDFATHERED PLAN NOTICES HEALTH FSAs All applicants and enrollees for all group health plans, excepted for those that are excepted benefits under HIPAA. WHO This requirement began with open enrollment periods after September 23, 2012. This is required to be sent annually. WHEN The purpose is to allow health care consumers compare coverage options and choose what is best for them. WHAT This requirement applies to all employers that are subject to the Fair Labor Standards Act. The notice must be sent to all current employees. WHO The notice must be sent no later than October 1, 2013. After that, the notice must be provided to all new hires at the time of hire. WHEN Information on: Existence of the Marketplace, services provided by the Marketplace, how employees may contact the Marketplace, etc. WHAT SUMMARIES OF BENEFITS & COVERAGE All employer-sponsored plans that offer a prescription drug benefit must annually notify participants as to whether their coverage is creditable or non-creditable. WHO The deadline to mail these notices is October 15 each year. WHEN This will require notices to go out prior to most plans being finalized. Any changes in creditable status once a plan is finalized will require another round of notices to be sent. WHAT With ACA, employers must notify participants of their right to designate any primary care provider who participates in the network. WHO Must be provided whenever the plan provides an SBC. Must be provided no later than the first day of the first plan year beginning on or after September 23, 2010, and annually thereafter. WHEN This notice provides information regarding rights to choose a primary care provider or obtain obstetrical or gyneological care without prior authorization. WHAT Open enrollment packet must be sent to: Possible Electees, Electees or Continuees. WHO This is a requirement that states employers provide the same rights to COBRA Continuees during an open enrollment period that are offered to active employees. WHEN The Open Enrollment Notification is required even if the only change is the COBRA rates. WHAT ACA requires that this notice be provided to all participants if the plan is to maintain its grandfathered status. WHO This requirement began with open enrollment periods after September 23, 2012. This is required to be sent annually as long as the group health plan maintains its grandfathered status. WHEN A notice explaining that the plan or coverage is a grandfathered health plan with the ACA definition. WHAT If the Health FSA is HIPAA-excepted and the employer need only offer COBRA when the FSA account is underspent, then the COBRA obligation ends at the end of the first plan year. WHO During open enrollment period. WHEN Included with open enrollment notification of available coverages. WHAT ANNUAL NOTICE COBRA QUALIFIED BENEFICIARY COMMUNICATIONS copyright 2013