Employers that sponsor group health plans may need to update those plans to comply with the new requirements of the federal Children's Health Insurance Reauthorization Act of 2009 ("CHIPRA"). CHIPRA reauthorized and expanded the scope of the State Children's Health Insurance Program (now known as CHIP) to permit state programs to provide qualifying children from low-income families with a premium subsidy toward enrollment in employer group health plans. However, what may be most relevant to employers is that CHIPRA created additional obligations for group health-plan sponsors, including new special enrollment rights – effective as of April 1, 2009 – as well as new notice and disclosure requirements and compliance penalties of up to $100 per day, per participant, for failure to comply with these notice and disclosure requirements.
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