In regard to extending coverage to adult dependents under age 26, can employers require adult children to complete enrollment applications?
If employers require all children to complete enrollment applications (even minor children), they can then require that adult children also complete applications. Plans cannot vary the terms of coverage for any dependents, except for children ages 26 and older). Plans should offer adult dependents coverage on the same basis as all other dependents with the same enrollment process. We have planned the special enrollment for adult dependents during our 2011 annual open enrollment period that runs for 2 weeks. Do we have to allow a 30-day enrollment window for the special enrollment? Yes. The special enrollment for dependent children must run 30 consecutive days, including written notice of the opportunity to enroll. When plans have annual open enrollment periods less than the required 30 days, they will need to extend the period for eligible dependents and their parents. The special enrollment period can run concurrently with annual open enrollment and employers can distribute notices wi