Life Changes Don’t Wait for Open Enrollment
Open enrollment may only happen once a year, but life happens all year long. Employees get married, welcome children, lose coverage, change jobs, or experience other major life events that may impact their benefits.
These events, known as Qualifying Life Events (QLEs) or midyear election changes, can allow employees to make changes to their benefit elections outside of open enrollment. Understanding these rules is critical for employers to remain compliant and provide a positive employee experience.
Recent guidance highlights that employers must administer these changes consistently and according to both federal law and plan documents.
Common Qualifying Life Events
Employees may be eligible to update their benefits when they experience events such as:
- Marriage or divorce
- Birth or adoption of a child
- Loss of other health coverage
- Changes in employment status
- Changes in dependent eligibility
- Loss of Medicaid or CHIP coverage
- Becoming eligible for a state premium assistance program
Most HIPAA special enrollment events require employees to request changes within 30 days, while Medicaid and CHIP events often allow 60 days.
Why Employers Should Pay Attention
Administering midyear changes incorrectly can create compliance issues and employee frustration. Employers should ensure:
1. Enrollment Deadlines Are Followed
Special enrollment rights are time-sensitive. Applying deadlines consistently across all employees helps reduce compliance risk.
2. The Change Matches the Event
Benefit changes must be consistent with the qualifying event. For example, gaining a dependent generally would not justify dropping coverage entirely.
3. Plan Documents Allow the Change
Not every midyear change is automatically permitted. Employers should periodically review their Section 125 cafeteria plan documents to ensure administrative practices align with plan rules.
4. Different Benefits Follow Different Rules
Health FSAs often have more restrictive rules, while HSA contribution elections may generally be changed throughout the year on a prospective basis.
How EPS Can Help
Managing employee benefits and compliance can quickly become complex—especially for growing businesses without dedicated HR staff.
At Eureka People Solutions (EPS), we help employers navigate:
- HR compliance and administration
- Employee benefit changes
- Leave management
- Handbook and policy updates
- Employee onboarding and offboarding
- Recruiting and HR consulting