This checklist will help ensure compliance with federal and state requirements, as well as internal processes, during open enrollment. Use it to verify that all necessary steps are completed on time and that employees are informed and supported throughout the enrollment period.
Prepare for Open Enrollment
☐ Determine Open Enrollment Dates
Confirm the start and end dates of the open enrollment period.
☐ Review Benefits Offerings
Verify benefits plans, costs, and coverage options for accuracy.
Confirm compliance with federal and state laws, such as the Affordable Care Act (ACA) requirements.
Ensure offerings meet non-discrimination requirements if applicable (e.g., health plans should not favor highly compensated employees).
☐ Plan & Distribute Employee Notices
Ensure timely distribution of required notices, including:
Summary of Benefits and Coverage (SBC)
Summary Plan Descriptions (SPD)
Summary of Material Modifications (SMM), if there are changes
Children’s Health Insurance Program (CHIP) Notice
Medicare Part D Notice, if applicable
☐ Finalize and Test Enrollment Platform
Ensure online enrollment systems are accessible and functioning.
Confirm platforms are updated with the correct benefits information, eligibility, and costs.
Conduct testing for any technical issues or accessibility concerns.
2. Compliance with Federal and State Requirements
☐ Affordable Care Act (ACA) Requirements
Confirm ACA eligibility for all employees (e.g., offering coverage to employees averaging 30+ hours per week).
Verify affordability of the plan for eligible employees to avoid ACA penalties.
Prepare to report ACA information on IRS Forms 1094-C and 1095-C.
☐ COBRA Compliance
Ensure continuation coverage options are available for eligible employees and dependents.
Provide COBRA election notices to qualified beneficiaries, as applicable.
☐ HIPAA Privacy Compliance
Confirm that employee data is protected and complies with HIPAA privacy and security rules.
Ensure that enrollment processes, including handling of sensitive health information, are HIPAA-compliant.
☐ FMLA and Leave Entitlements
Ensure employees on Family and Medical Leave Act (FMLA) or other approved leaves are notified and given the opportunity to enroll or make changes.
☐ ERISA Compliance
Review requirements under the Employee Retirement Income Security Act (ERISA) for private-sector health plans.
Ensure proper documentation and disclosure of plan terms, fees, and eligibility.
3. Communication with Employees
☐ Provide Clear Enrollment Instructions
Send step-by-step instructions for enrollment to all employees, with deadlines and contact information for support.
Confirm that instructions cover dependent verification and required documents for adding dependents.
☐ Schedule Information Sessions
Offer virtual or in-person sessions to explain benefit changes, answer questions, and review plan options.
Make recordings available for remote and asynchronous access if possible.
☐ Provide Plan Comparison Tools
Share tools or resources (e.g., cost calculators, FAQs) to help employees compare plans and understand their options.
☐ Distribute Voluntary and Ancillary Benefits Information
Highlight any voluntary benefits (e.g., vision, dental, life insurance, disability, wellness programs) and provide enrollment instructions.
☐ Update Required Notices on Employee Portals
Post all necessary open enrollment documents and notices (e.g., SBC, SPD) on the employee portal for easy access.
4. Enrollment and Documentation
☐ Track Enrollment Elections and Changes
Monitor enrollment progress and track changes made by employees to ensure that all elections are processed.
Verify that dependent eligibility documents are collected and recorded.
☐ Ensure Payroll Adjustments Are Scheduled
Coordinate with payroll to schedule deductions or adjustments to contributions based on employee elections.
☐ Verify Waivers of Coverage
Ensure employees who waive coverage understand the implications and complete any required documentation.
☐ Document Changes in Compliance with ERISA
Keep detailed records of plan modifications, summaries of material modifications (SMM), and employee communications.
5. Post-Enrollment Review and Reporting
☐ Audit Enrollment Data
Review and confirm accuracy of all data entered, including coverage details, dependent information, and payroll deductions.
☐ Conduct Non-Discrimination Testing (if applicable)
For applicable employers, conduct annual non-discrimination testing for self-insured health plans, wellness programs, and cafeteria plans.
☐ Issue Confirmation Statements to Employees
Provide each employee with a benefits confirmation statement summarizing their chosen elections and deductions.
☐ File ACA Reporting Forms
Prepare and submit IRS Forms 1094-C and 1095-C by the deadlines.
6. Continuous Improvement
☐ Gather Employee Feedback on Open Enrollment
Send a post-enrollment survey to gather feedback on the enrollment experience, communication, and tools provided.
☐ Evaluate and Document Open Enrollment Process
Assess any issues encountered, document them, and plan improvements for next year’s open enrollment cycle.
This checklist will help ensure a compliant, organized, and employee-friendly open enrollment period. Regularly reviewing and updating the checklist is recommended to stay compliant with changing regulations and to continuously enhance the employee experience.
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