Automatic Medical Plan Enrollment Presents Challenges  

Interesting commentary on the not-yet implemented “auto-enrollment” feature of the ACA. The requirement does not go into effect until the DOL issues regulations -- which we have not seen yet. In this article, Mercer’s Terry Dailey points out that one of the potential negative employee relations issues is that the medical plan enrollment typically includes a pre-tax payroll deduction that precludes an employee from changing their election once open enrollment closes unless they have a qualifying event. Could this possibly trigger employers to consider auto-enrollment with post-tax contributions -- if/when auto-enrollment is required?