The U.S. Department of Labor (DOL), through the Employee Benefits Security Administration (EBSA), has released a revised model Employer CHIP Notice with state-specific premium assistance information current as of July 31, 2025.
Annual Notice Requirement for Employers
Under the Children’s Health Insurance Program Reauthorization Act of 2009 (CHIPRA), employers that maintain group health plans must provide an annual notice to employees residing in states offering premium assistance subsidies through Medicaid or a Children’s Health Insurance Program (CHIP).
This notice may be delivered:
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Separately on its own;
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With materials informing employees of health plan eligibility;
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During open enrollment or benefit election periods; or
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With the summary plan description (SPD).
Who Must Comply?
An employer is subject to this requirement if their group health plan covers any employees who reside in a state offering premium assistance—regardless of where the employer is located. Even multi-state employers with only a few eligible participants in applicable states must comply.
The model notice is updated periodically and includes contact details for applicable state programs. Employers may use the model as-is or tailor their own version, provided they include all minimum required information for each relevant state.
Reminder: Employers should review their open enrollment communications to ensure the current CHIP Notice is included for applicable employees. Including it alongside other enrollment materials helps streamline compliance and administration.
This Legal Update is not intended to be exhaustive nor should any discussion or opinions be construed as legal advice. Readers should contact legal counsel for legal advice. ©2025 Zywave, Inc. All rights reserved.