The Department of Labor (DOL) released a new model notice regarding premium assistance under Medicaid or the Children’s Health Insurance Program (CHIP). The prior model notice expired October 31, 2016. Employers providing coverage in states offering premium assistance through Medicaid or CHIP are required to provide an annual notice to every employee, regardless of enrollment status, of the opportunity for state assistance to obtain health coverage.
The new model notice can be found here.
Employers can use the DOL’s model notice to satisfy their obligation under ERISA.
Lockton comment: For employers that issued the prior Medicaid/CHIP notice (which expired October 31, 2016) with open enrollment materials, rest easy; the DOL will not penalize those employers who continued to provide the prior DOL model notice.
Health Insurance Marketplace Coverage Model Notice
And speaking of model notices, the model Health Insurance Marketplace Coverage notice is set to expire January 31, 2017. To date, an updated model notice has not been provided by the DOL. Until an updated model notice is provided, use of the current notice will likely satisfy the employer’s Affordable Care Act notice requirements.