What Employers Need to Know About Special Enrollment for Employees Formerly on Medicaid

Haynsworth Sinkler Boyd, P.A.
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Haynsworth Sinkler Boyd, P.A.

The expanded Medicaid and CHIP coverage offered during the COVID-19 public health emergency ended March 31, 2023, and employees and dependents who were participating in the expanded government-provided health insurance were disenrolled from those coverages Friday.

Employers will need to prepare for employees and their dependents who lost coverage to seek coverage under their employers' healthcare plans. Group health plans and employers must offer impacted employees and their dependents a special enrollment period until July 10, 2023, per an earlier notification issued by the Department of Labor, the Treasury Department and the Internal Revenue Services as part of their notice extending special enrollment deadlines during the pandemic. The Departments also encourage plans and employers to consider implementing lengthier special enrollment periods beyond July 10, 2023.

Employers and plans should also notify those impacted employees of their special enrollment rights to enroll in the group health plans. The Department of Labor created a flyer to provide to impacted employees.

Cessation of expanded enrollment under Medicaid and CHIP are the precursors to the May 11, 2023, end of the COVID-19 Public Health Emergency (PHE). The end of the PHE carries some changes and considerations for employer healthcare plans and health insurers.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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