For a January 1 plan year, open enrollment is a six-week project: the notices, the files and the numbers need owners before employees see anything.
This checklist works backward from the January effective date. Some deadlines for a 2027 plan year have already passed, so it flags what to send late and what still has time.
The notices to send with enrollment materials.
Medicare Part D Creditable Coverage Notice
Employers that offer prescription coverage to Medicare-eligible people must send the notice before October 15 each year. If it was missed, send it now and document the date.
Summary of Benefits and Coverage
The SBC is provided with open enrollment materials and again on request. Confirm you hold the current SBC for every plan before the packet is built.
Annual Plan Notices
Women’s Health and Cancer Rights Act and CHIP notices are annual items for group health plans. Check that your packet includes both.
ICHRA and QSEHRA Notice
A reimbursement arrangement that starts January 1 needed its written notice 90 days earlier. If that date passed, speak with counsel about timing.
Wellness and Incentive Notices
Programs with incentives can carry their own notice requirements. Review them before the offer goes out.
Late-Notice Triage
If a notice was missed, send it, document the date, and fix the calendar so it does not recur next year.
The numbers to confirm before rates go out.
Check the 2027 Limits
HSA, HDHP, ACA out-of-pocket and affordability figures for 2027 are published. Confirm each against the page before anything is printed.
Test Contribution Affordability
The 2027 percentage is 10.22 percent. Run every rate tier against the three safe harbors before announcing employee contributions.
Reconcile Rates and Eligibility
Match carrier rates, plan names and eligibility rules against the enrollment platform. A rate typo found in January costs more than one found now.
Confirm Waiting Periods
New hires and rehires follow the waiting period in the plan document. Verify the date logic in your system.
What employees need and when.
Plan Comparison and Cost Examples
A one-page comparison with cost examples works better than a long guide. Show the full-year cost for a typical employee.
Meetings, Reminders and Deadlines
Hold meetings early in the window, send reminders at the halfway point and the last week, and set one deadline.
Support After Enrollment
Employees will have questions in January. Decide who answers them and how, including after hours.
What to settle before the window opens.
Which notices are late, and by how much?
List every notice with its due date and owner. Missed ones should be sent now and logged.
Do rates and eligibility match the platform?
Reconcile before the first employee logs in. Errors found after elections are expensive to correct.
Who answers employee questions in January?
Name the person or team and publish the contact path in the packet.
What happens to waived coverage?
Confirm what waiver requires, whether there is an opt-out payment and how it affects ACA affordability.
The questions employers ask about open enrollment.
When should open enrollment start for a January 1 plan year?
Most employers open the window four to six weeks before the plan year, so a mid-November start leaves time for corrections. Build the notices and rate checks before that date.
Which notices go out with open enrollment?
The Summary of Benefits and Coverage, the Women’s Health and Cancer Rights Act notice, the CHIP notice and any plan-specific notices. The Medicare Part D creditable coverage notice is due before October 15.
What if we missed the Medicare Part D notice?
Send it as soon as possible and keep a record of the date. Ask your compliance advisor whether any further action is needed.
Do we need to test ACA affordability before open enrollment?
Yes. Employee contributions for the lowest-cost self-only plan must stay below the 2027 percentage of 10.22 percent under one of the safe harbors.
What should be in an open enrollment packet?
Plan comparison with cost examples, a calendar of deadlines, how to enroll, required notices, and who to contact with questions.
How do we handle employees who waive coverage?
Confirm the waiver process, whether an opt-out payment is offered and how it interacts with ACA affordability.
How long should open enrollment last?
Two to three weeks is common for the window itself, with earlier communication. A longer window rarely improves participation.
What happens after enrollment closes?
Reconcile elections with carrier files, confirm payroll deductions and handle late changes through qualifying life events.
General information about open enrollment, not legal advice. Notice and compliance questions belong with ERISA counsel, and we will bring them in.
Where these details come from.
This page summarizes public guidance reviewed in October 2026. Notice timing and rules change, so confirm with counsel.
U.S. Department of Labor: Employee Benefits Security Administration →
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