Renewal Season Checklist

As renewal season approaches, employers should take a proactive approach to reviewing their health and welfare benefit offerings. This is the ideal time to align plan design, documentation, and administration with federal and state requirements, while also confirming that carriers and vendors are prepared to support the upcoming plan year. Careful planning reduces compliance risk, ensures employee communications are accurate, and helps avoid costly corrections later. The following checklist highlights key compliance priorities for employers.

Renewal Checklist

Plan Design & Documentation

• Review and update plan documents (wrap plan/SPD, cafeteria plan document, SBC) to reflect current benefit offerings and service providers.
• Review eligibility rules (for employees and dependents), including during leaves of absence, and make sure they’re consistent across all plan documentation.
• Evaluate benefit expansions or exclusions to ensure compliance with ACA, MHPAEA, and nondiscrimination requirements and update plan documents accordingly.
• Update account-based plan limits (FSAs, HSAs, HRAs, DCAPs) for the upcoming tax/plan year. Ensure any grace periods, carryovers or spend-down provisions are correctly described.
• Review grandfathered plan status, if applicable

Eligibility Tracking

• Confirm eligibility rules, including any measurement and stability periods, are properly programmed into payroll and benefit administration systems.
• Confirm waiting period rules and break in service (or rehire) provisions are set up correctly.

Contributions & Affordability

• Ensure employee contributions for single medical coverage meet an ACA affordability safe harbor for any applicable large employer.
• Confirm pre-tax and after-tax deductions are set up correctly in payroll (e.g., premiums for disability coverage and life insurance above $50,000 as well as premiums for domestic partners and owners are all generally taxable).
• Audit payroll and benefit systems to ensure contributions are accurate and aligned with benefit elections.
• Update benefit levels that are based on income levels (e.g., life and disability insurance).

Enrollment Materials & Notices

• Clarify open enrollment time frames and whether open enrollment is passive (no action needed unless a change in election is desired) or active (must take action to enroll in benefits for the upcoming plan year).
• Distribute open enrollment materials and required annual notices (e.g., SBC, WHCRA, CHIP, Medicare Part D Creditable Coverage). Remember to provide materials to COBRA participants and retirees in addition to active employees.
• Update and collect employee attestations where applicable (e.g., HRA integration with a spouse’s plan, eligible opt-out arrangements, ICHRA integration with an individual plan or Medicare, HSA contributions for outside HDHP coverage, completion of wellness program requirements).

Compliance Assessment

• Conduct nondiscrimination testing and make any necessary adjustments for highly compensated or key employees prior to plan year-end.
• Audit plan operations for compliance with ERISA, COBRA, HIPAA, ACA and MHPAEA.
• Confirm service providers (e.g., carriers, TPAs, PBMs) are meeting contractual and compliance obligations. Request NQTL comparative analysis, fee disclosures, and other documentation as needed.
• Prepare or update a compliance calendar to track notice distribution and filing deadlines (e.g., Form 5500, ACA reporting, Gag Clause Attestation).