2024 Open Enrollment Compliance Checklist

To get ready for open enrollment, employers who sponsor group health plans should be aware of the legal changes affecting the design and administration of their health plans for plan years beginning on or after Jan. 1, 2024. These changes include limits that are adjusted for inflation each year, such as the Affordable Care Act’s (ACA) affordability percentage and cost-sharing limits for high deductible health plans (HDHPs). Employers should review their health plan’s design to confirm that it has been updated, as necessary, for these changes.

In addition, any changes to a health plan’s benefits for the 2024 plan year should be communicated to plan participants through an updated summary plan description (SPD) or a summary of material modifications (SMM).

Health plan sponsors should also confirm that their open enrollment materials contain certain required participant notices, when applicable, such as the summary of benefits and coverage (SBC). Some participant notices must also be provided annually or upon initial enrollment. To minimize costs and streamline administration, employers should consider including these notices in their open enrollment materials.

Plan Design Issues

• Applicable large employers (ALEs) should confirm that at least one of their health plans offered to full-time employees satisfies the ACA's affordability standard.
• For HDHPs, employers should confirm that the plan’s deductible and out-of-pocket maximum comply with the 2024 limits.
• Employers should communicate plan design changes to employees as part of the open enrollment process.

View and download the full 2024 Open Enrollment Compliance Checklist.