New FAQs from CMS Regarding SHOP

Here's something that wasn't addressed, and could have an impact.

If a group shops through the SHOP exchange, and decides to make a change and offer a plan through the SHOP, the open enrollment is from 11/15-12/15 (which is a VERY narrow window, as those of us who do group already know - but that's another issue).

According to standards set within the ACA, notifications for material changes to plan design (we can argue about "material" changes all day long) must go out to employees 60 days prior to the plan change.

So does that mean that plans offered through the SHOP create a non-compliant situation?
 
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