Interim Final Rules on Dependent Coverage of Children Update

Interim final rules on extending health insurance coverage for adult children up to age 26 have been issued. These regulations apply for health plans beginning on or after September 23, 2010.  For a calendar year plan, the coverage, if elected, must be effective no later than January 1, 2011. 

The regulation can be found at:  http://www.dol.gov/ebsa/pdf/dependentcoverage.pdf

A fact sheet can be located on the Department of Labor website:  http://www.dol.gov/ebsa/newsroom/fsdependentcoverage.html

A Q&A sheet for young adults can also be found on the Department of Labor website at:  http://www.dol.gov/ebsa/faqs/faq-dependentcoverage.html

Plans that currently limit a child’s eligibility’s factors based on factors such as student status, marital status, etc., or have age limits lower than age 26 will need to be revised to meet these new regulations. There are many areas for a plan to consider to be compliant – for example, a special enrollment period must meet the date boundaries defined by the regulations;  coverage can be made with pre-tax dollars;  COBRA continuation coverage processes may be affected; etc.  For health plans that meet the grandfather definition, there are some very limited exceptions and clarifications due out soon.