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Compliance Checklist for 2020 Annual Enrollment

Compliance Checklist for 2020 Annual Enrollment
Posted on Friday, September 27, 2019 by Bruce Gillis

It’s that time of year again—football is on TV, the temperature is slowly beginning to drop, and we are all working on annual enrollment. 

As you finalize and execute your annual enrollment plans—here are some additional items to consider:2020-compliance-checklist

As you finalize and execute your annual enrollment plans—here are some additional items to consider:

  1. Updated Participant Communications – Plans may need to be updated to reflect a variety of new developments, including:
  • Increased State Individual Mandate requirements – Beginning in 2020, the states/locales that currently have individual mandate requirements (Massachusetts, New Jersey, and Washington, DC) will be joined by California, Vermont and Rhode Island. Multiple other states are also considering such legislation, which assigns a financial penalty for residents that do not enroll in health coverage.
  • Are your plan documents current? Some documents, such as the CHIP notice (see here) have been updated this year. Review your documents to ensure you have the latest versions.
  • Are you implementing a new Individual Coverage Health Reimbursement Arrangement (ICHRA) effective with the new plan year? If so, the Department of Labor has a required notice that should go out 90 days prior to the start of the plan year to any plan participant eligible for the ICHRA. Check out the model notice for the ICHRA here.
  1. Have you mailed your Medicare Part D Notices of Creditable Coverage? These notices are required by 10/15 each year.
  2. The new Medicare ID transition period is almost up! As a reminder, Medicare has replaced the SSN-based participant ID (the Health Insurance Claim Number, or HICN) with a non-SSN based alpha-numeric ID. CMS will be accepting the old identifier through the end of 2019 and after which time, they will require the new identifier. If you interface with CMS for any reason, and still have the SSN-based HICNs for your active Medicare population, you may want to consider soliciting your Medicare- entitled individuals for their updated identifiers.
  3. Hurricane Relief – While not annual enrollment related, it’s about that time of year that the DOL evaluates and provides relief for victims of natural disasters that occur in the fall, for example, the recent Hurricane Dorian and the flooding in Texas. If you have employees in these areas, you may want to evaluate whether you will be providing any relief to these populations. For more information on historical DOL relief guidance, see here. Typically, employer-provided relief takes the form of additional time for enrollments or possibly extra time for COBRA payments.

And finally, looking down the road, I know that everyone may have been hoping that we have heard the last of the PCORI counts and fees, but there are a couple of bills in the House that include language that would extend the PCORI count and payment processes. These bills are only proposed as this point, but we want to keep this on your radar as we look ahead for 2020. 

Have more compliance questions? 


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Bruce Gillis Head of Compliance Lorem ipsum dolor sit amet. View All Posts