Run: Open Enrollment Communications Policy

This policy establishes a consistent, documented process for communicating open enrollment timelines, distributing benefits materials, providing a channel for employee questions, and confirming receipt of enrollment information and elections. The policy is intended to support clear employee communications, reduce missed deadlines, and promote compliance with applicable benefits notice requirements.

This policy applies to all eligible employees, HR/Benefits staff, managers who may receive employee questions, and any third-party benefits administrators involved in the open enrollment process. It applies to annual open enrollment communications and any special enrollment communications issued by the policy holder. **Jurisdiction-specific note:** California employees, New York employees, and other state-specific populations must receive any additional notices required by applicable state law or plan terms. Where state law provides greater employee rights, the more protective requirement applies.

For purposes of this policy, the following terms apply: - **Open Enrollment Timeline:** The published schedule for announcement, materials release, Q&A deadline, election window, reminder notices, and final confirmation deadline. - **Benefits Materials:** Enrollment guides, plan summaries, premium rate sheets, carrier information, SBCs, and any required legal notices. - **Q&A Submission Window:** The period during which employees may submit questions about plan options, eligibility, deadlines, or enrollment steps. - **Confirmation Requirement:** The required employee acknowledgement that they received the open enrollment notice and, where applicable, completed elections or waived coverage. - **Accessible Format:** A communication format that is reasonably accessible to employees, including accommodations for employees with disabilities under the ADA interactive process.

The policy holder will communicate open enrollment information in a timely, accurate, and accessible manner. Communications must clearly state the enrollment start date, end date, effective date of coverage changes, where to find benefits materials, how to submit questions, and how to confirm receipt or submit elections. Open enrollment communications must be distributed using at least one primary company channel and one backup channel, such as email, intranet, HR portal, or mailed notice for employees without regular system access. Communications must be written in plain language and must not be misleading, incomplete, or inconsistent with plan documents. The policy holder will make reasonable efforts to ensure employees receive the information needed to make informed elections, including the SBC and any required notices. If an employee requests an accommodation to access enrollment materials, HR will engage in the ADA interactive process and provide a reasonable accommodation where appropriate. The policy holder will not retaliate against employees for asking questions, requesting clarification, or raising concerns about benefits communications. Nothing in this policy limits rights protected by the NLRA, including concerted activity regarding wages, hours, or working conditions.

1. **Publish the timeline:** HR/Benefits will publish the open enrollment calendar at least 30 days before the enrollment window opens, unless a shorter period is required by plan administration or law. The calendar must include announcement date, materials release date, Q&A deadline, enrollment deadline, and confirmation deadline. 2. **Distribute materials:** HR/Benefits will provide enrollment guides, plan comparisons, SBCs, premium contributions, eligibility rules, and any required notices through the designated communication channels. 3. **Provide Q&A process:** Employees must be told how to submit questions, including the email address, portal form, or helpdesk contact. HR/Benefits will publish a response target and identify which questions must be escalated to the carrier, broker, or legal counsel. 4. **Send reminders:** HR/Benefits will issue at least one reminder before the enrollment deadline and one final reminder near the close of the enrollment window. 5. **Collect confirmations:** Employees must confirm receipt of the enrollment notice and, where applicable, submit elections or a waiver by the stated deadline. The confirmation method may be electronic or paper-based, depending on employee access. 6. **Track exceptions:** HR/Benefits will document employees who did not confirm receipt, missed the deadline, or requested assistance, and will follow up using the approved escalation process. 7. **Archive records:** HR/Benefits will retain copies of communications, confirmations, and enrollment-related notices in accordance with the company retention schedule and applicable law. **FLSA note:** Communications and enrollment administration must be structured so that non-exempt employees are not required to perform off-the-clock work to review materials or complete elections. If time spent is work time under applicable law, it must be handled consistently with FLSA requirements.

- **Policy Holder / HR Director:** Approves the annual communication plan, ensures legal review where needed, and resolves escalated issues. - **HR/Benefits Team:** Prepares and distributes enrollment materials, manages the Q&A process, tracks confirmations, and maintains records. - **Managers:** Reinforce deadlines, direct employees to HR/Benefits for plan questions, and avoid giving plan advice unless authorized. - **Employees:** Review materials, submit questions by the stated deadline, and complete confirmations/elections on time. - **Third-Party Administrator / Broker:** Provides plan information, supports technical enrollment issues, and assists with carrier-specific questions as authorized.

Failure to follow this policy may result in delayed enrollment, loss of benefit elections, or other administrative consequences permitted by plan terms and law. HR/Benefits must document missed deadlines, incomplete confirmations, and unresolved communication issues. If communications are inaccurate, late, or inaccessible, the policy holder must investigate the issue, issue a corrective notice if needed, and determine whether an extension or other remedy is required under plan rules or applicable law. Employees who intentionally misuse the Q&A process, submit false information, or interfere with the enrollment process may be subject to documented warning, coaching, or a PIP, depending on the severity and frequency of the conduct. Any discipline must be applied consistently and without discrimination under Title VII, the ADA, the ADEA, or other applicable laws.

This policy will be reviewed annually and whenever there is a material change to benefits offerings, enrollment systems, communication channels, or applicable law. Revisions must be approved by the policy holder and, where appropriate, reviewed by legal counsel, benefits counsel, or the plan administrator before publication.