What a busy time of year for most of us in the benefits arena. ‘Tis the season. In the midst of open enrollment chaos, employers are inundated with the frenzy of work and planning to ensure that employees are set for their new year. But what I’m always concerned about is what employers may be overlooking at this time of year. The big items, like medical and dental open enrollment requirements, are usually at the forefront and not forgotten. But then there are the things which get pushed to the side and deemed less significant – things which can actually tend to be not so insignificant if overlooked.
One example: employers sometimes forget – or don’t know – that while IRS regulations do allow for automatic rollover of FSA elections, it is not common practice and not recommended. So, have you considered how you are handling this – and if necessary, did you remember to notify your employees to actively re-enroll in healthcare and dependent care FSA for the new plan year?
Then there’s my favorite: COBRA. Again, some plan sponsors don’t realize that COBRA participants must be offered the same open enrollment opportunities as active employees as they apply to medical, dental and vision – even including HRA plans. Did you know that if you are implementing a new vision plan, that vision benefit must also be offered to your COBRA participants? I often hear a chorus of, “But they weren’t covered under a vision plan when they were active employees.” Doesn’t matter, the new benefits must be offered to the COBRA participants as though they were active employees. Same goes if you are implementing a new HRA plan to go along with a HDHP. The HRA component must be offered to your COBRA members.
If you are one of those who is thinking, “Oops…I overlooked one of these”, don’t panic – it’s not too late to rectify. Your FSA and/or COBRA administrator(s) should be able to help. And then be sure to add these to your checklist for next year.