New Participation Requirement for Small Group Direct Plans

For small group fully insured direct plans with an effective date of August 1, 2017 or later, the participation requirement has changed.

New requirement: 50% of all eligible employees must participate, except those with valid waivers. Other comprehensive coverage of any kind, including a Medicare or Medicaid plan, is considered a valid waiver. Non-comprehensive coverage includes mini-meds, short-term, and indemnity plans.

Previous requirement: 50% of eligible employees must participate.

If you have a small group with an August 1 or later effective date whose application for a direct plan was denied for not meeting the participation requirement, contact your client consultant to see if the group meets the new requirement.