Relating to the enrollment period for newborns under certain health benefit plans.

Contracts

• Carrier Policies: Review your 2026 renewal documents. Ensure the policy explicitly cites the 60-day newborn enrollment period. Do not sign a policy containing the obsolete 31-day limitation.
• TPA Agreements: If self-funded but opting into compliance (to match stop-loss requirements), amend your Third-Party Administrator Service Level Agreement (SLA) to extend the processing window.

Hiring/Training

• HR Protocols: Train benefits staff to stop citing the "31-day rule" for 2026 plans. Misinforming an employee that they missed the deadline on Day 45 will create employer liability for medical costs.
• Payroll Coordination: Prepare for larger retroactive deductions. Adding a dependent on Day 59 triggers two months of retroactive premiums in a single pay cycle. Payroll staff must be trained to warn employees of this financial impact.

Reporting & Record-Keeping

• Summary Plan Descriptions (SPDs): You must amend all employee-facing benefits guides and SPDs for the 2026 plan year to reflect the 60-day window.
• BenAdmin Systems: Contact your software vendors (Workday, ADP, Paycom, etc.) immediately to reconfigure the "Newborn" QLE logic. The system must not auto-reject applications submitted between Day 32 and Day 60.

Fees & Costs

• Premium Catch-Up: There are no new state fees. However, the business must budget for the administrative cost of reprocessing claims if a newborn is added late in the 60-day window, requiring retroactive carrier adjustments.