2021 Open Enrollment Checklist for Small Business Employers

To prepare for open enrollment, group health plan sponsors should be aware of the legal changes affecting the design and administration of their plans for plan years beginning on or after January 1, 2021.

Plan Design Changes

There are a variety of plan design changes to be aware of for plan years beginning on or after January 1, 2021, including:

• Affordable Care Act (ACA) affordability standard – The affordability percentage for 2021 is 9.83%.
• Out-of-pocket maximum (OOPM) – The annual OOPM limit for 2021 is $8,550 for self-only coverage and $17,100 for family coverage.
• High deductible health plan (HDHP) and health savings account (HSA) limits for 2021:
  • HSA contribution limits: $3,600 for individuals/ $7,200 for families
  • HDHP minimum deductible: $1,400 for individuals/ $2,800 for families
  • HDHP OOPM limit: $7,000 for individuals/ $14,000 for families

Employer Action Steps

Changes to a health plan’s benefits for the 2021 plan year should be communicated to eligible employees in advance of open enrollment. Plan participants may also need to be informed of some changes through an updated summary plan description or a summary of material modifications.

Open Enrollment 2021 – Benefits Notices

Employers that sponsor group health plans should provide certain benefits notices in connection with their plans’ open enrollment periods. Some of these notices must be provided at open enrollment time, such as the Summary of Benefits and Coverage (SBC).

Other notices, such as the Women’s Health and Cancer Rights Act (WHCRA) notice, must be distributed annually. Although these annual notices may be provided at different times throughout the year, employers often choose to include them in their open enrollment materials for administrative convenience.

In addition, employers should review their open enrollment materials to confirm that they accurately reflect the terms and cost of coverage.

Below is a list that summarizes the applicability of the benefits notices employers should provide. Note, the following chart is not exhaustive and only includes the notice title and its applicability.

• Summary of Benefits and Coverage (SBC) – Group health plans and health insurance issuers
• Summary Plan Description (SPD) – Group health plans subject to ERISA
• Medicare Part D notice of creditable or non-creditable coverage – Employers with group health plans that provide prescription drug coverage
• WHCRA notice – Group health plans that provide medical and surgical benefits for mastectomies
• Children’s Health Insurance Program (CHIP) notice – Group health plans that cover residents in a state that provides a premium assistance subsidy under a Medicaid plan or CHIP
• COBRA general notice – Group health plans subject to COBRA
• Grandfathered plan notice – Plans that have grandfathered status under the ACA
• Notice of patient protections – Non-grandfathered group health plans that require designation of a participating primary care provider
• HIPAA privacy notice – Self-insured group health plans
• HIPAA special enrollment notice – All group health plans
• HIPAA Wellness notice – Group health plans with health-contingent wellness programs
• ADA Wellness notice – Wellness programs that collect health information or include medical exams
• Individual coverage HRA (ICHRA) – Employers that sponsor ICHRAs for specific classes of employees (or all employees)

For more details about a specific benefits notice or its requirements, speak with TransGlobal Benefits.

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