Reform Alert - News from the Blues' Office of National Health Reform

Coming soon: Special enrollment period to add or re-enroll eligible dependents

Aug. 20, 2010

For individual health plans and group health plans that offer dependent coverage, health insurers and employers are required by the Patient Protection and Affordable Care Act (PPACA) to hold a special enrollment period to add or re-enroll dependents up to age 26 that are now eligible for coverage under PPACA.

PPACA removes lifetime dollar limits from all health plans. Individuals who previously reached their lifetime dollar limit can also be added or re-enrolled during the special enrollment period.

Special enrollment period

Blue Cross Blue Shield of Michigan and Blue Care Network will hold the special enrollment period for individuals impacted by the provisions to extend dependent coverage and remove lifetime dollar limits from Nov. 1 through 30, 2010. This special enrollment period is only for individuals impacted by these two provisions. 

The coverage effective date for enrollment is Jan. 1, 2011, with the exception of groups that have a plan year that begins between Sept. 23 and Dec. 31, 2010. In this case, the coverage effective date is the plan year start date.

If a group routinely conducts its open enrollment from Oct. 1 through Dec. 31, then the group may use its normal open enrollment period as an opportunity to enroll those impacted by the two provisions, as long as it is at least 30 days in duration. Groups with a documented plan year between Jan. 2 and Sept. 22, 2011 can use their normal open enrollment period as long as it is 30 days in duration.

Grandfathering

PPACA prohibits both of these provisions from being grandfathered; therefore all groups must hold a Special Enrollment Period in order to comply with the regulations. However, until 2014, employers who are considered grandfathered have the option of excluding employees’ adult children if they are eligible for coverage under their employer’s health plan.

The information on this website is based on BCBSM's review of the national health care reform legislation and is not intended to impart legal advice. Interpretations of the reform legislation vary, and efforts will be made to present and update accurate information. This overview is intended as an educational tool only and does not replace a more rigorous review of the law's applicability to individual circumstances and attendant legal counsel and should not be relied upon as legal or compliance advice. Analysis is ongoing and additional guidance is also anticipated from the Department of Health and Human Services. Additionally, some reform regulations may differ for particular members enrolled in certain programs such as the Federal Employee Program, and those members are encouraged to consult with their benefit administrators for specific details.

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