Open Enrollment Starts Now: A Pre-Season Checklist for HR and Finance
An open enrollment preparation checklist covers the decisions, numbers, notices, and staffing you settle before enrollment materials reach employees. The start date isn’t a preference. Work backward from the fixed dates, because two of them are set by regulation and neither moves for you.
When should open enrollment preparation start?
Work backward from the day your enrollment materials go out. Your Summary of Benefits and Coverage has to travel with those materials, so the SBC has to be final first. Medicare Part D creditable coverage notices are due prior to October 15 each year, whenever your window opens.
The rule is specific. Under 29 CFR 2590.715-2715, the SBC “must be provided as part of any written application materials that are distributed by the plan or issuer for enrollment.” If you don’t distribute written application materials, it is due “no later than the first date on which the participant is eligible to enroll.”
That sentence sets your real deadline. The SBC reflects deductibles, out-of-pocket maximums, and coverage examples, so none of it can be finished until Plan design and contributions are settled.
What belongs on an open enrollment preparation checklist?
Seven items, in this order: settle Plan design and contributions, load the 2027 statutory limits, finalize the Summary of Benefits and Coverage, build the notice calendar, test the enrollment platform, brief everyone who will answer employee questions, and confirm HR and finance are working from the same numbers.
- Settle Plan design and contributions. Nothing downstream can be drafted until these are final, because every number an employee sees traces back to them.
- Load the 2027 statutory limits. Revenue Procedure 2026-24 has them, so there’s no reason to model next year on this year’s figures.
- Finalize the Summary of Benefits and Coverage. It has to be ready before enrollment materials go out.
- Build the notice calendar. Put every required notice on one calendar with a name against each.
- Test the enrollment platform. Run a real election end to end, including a dependent add and a waiver.
- Brief everyone who will answer questions. The people taking calls need answers before the first call.
- Confirm HR and finance are working from the same numbers. The rates on the enrollment screen and the rates in the budget model should match.
The list is short on purpose. A checklist nobody finishes isn’t a checklist. For what happens once the window opens, see our open enrollment best practices.
Which 2027 numbers should be locked before materials go out?
The IRS published the 2027 amounts in Revenue Procedure 2026-24. HSA contributions cap at $4,500 for self-only coverage and $9,000 for family coverage. A qualifying high deductible health plan carries a minimum annual deductible of $1,750 self-only and $3,500 family, with out-of-pocket maximums of $8,700 and $17,400.
An HDHP, or high deductible health plan, meets the IRS minimum deductible and maximum out-of-pocket thresholds for a year. An employee can contribute to a health savings account only while covered by one. Drop a 2027 self-only deductible below $1,750 and the HSA goes with it.
Two more figures belong in that file. The maximum amount that may be newly made available under an excepted benefit HRA for plan years beginning in 2027 is $2,250. The IRS also set the 2027 required contribution percentage at 10.22% in Revenue Procedure 2026-26, which governs whether employer coverage counts as affordable for the premium tax credit under section 36B.
These figures drive the contribution model, so finance needs them before HR drafts a single communication. Locking them once means one pass through the budget instead of two.
What notices have to go out, and by when?
Three carry fixed timing. The Medicare Part D creditable coverage notice goes to all Medicare eligible individuals prior to October 15 each year. The Summary of Benefits and Coverage travels with your written enrollment materials. A mid-year Plan change that alters SBC content requires notice 60 days before it takes effect.
Creditable coverage is prescription drug coverage that CMS describes as “expected to pay on average as much as the standard Medicare prescription drug coverage.” The annual notice tells Medicare eligible employees whether yours qualifies, which is what lets them decide about Part D. CMS requires it “prior to October 15th each year” and publishes model notice letters.
The recipient list is broad. CMS names Medicare eligible active employees and their dependents, Medicare eligible COBRA individuals and dependents, Medicare eligible disabled individuals covered under the drug plan, and retirees and their dependents.
The 60-day rule applies to changes made outside of renewal. If you modify the Plan mid-year in a way that changes SBC content, enrollees get notice at least 60 days beforehand.
Where do HR and finance fall out of sync?
On timing and on numbers. HR builds the enrollment calendar around employee availability. Finance builds the contribution model around the budget cycle. When those two run on separate tracks, employees see rates finance hasn’t approved, or finance approves rates after the communications are printed.
The fix is one pre-season meeting with a single agenda: the numbers. Contribution rates by tier. Employer cost at current and projected enrollment. The 2027 HSA and HDHP thresholds from Revenue Procedure 2026-24. The affordability calculation. Whoever owns the budget and whoever owns the enrollment platform leave with the same figures.
For a self-funded employer the stakes are higher, because the contribution model and the Plan’s funding assumptions are one conversation. Fixed costs, expected claims, and stop loss premium all feed the rate. A rate set without them looks approved and isn’t.
Who answers the questions once enrollment opens?
Someone should, and it shouldn’t be one person with a full inbox. Decide before the window opens who takes employee questions, on which channels, and with what backup. Plan for the first week to be the heaviest, because an unanswered question in week one becomes a wrong election in week three.
Channel mix matters more than channel count. Employees who don’t sit at a desk won’t see an email, which is why support that combines phone, text, and onsite help reaches people email never will.
Decide now whether your team carries that alone. Totem’s Benefits Service Center exists for this reason: employees call a person who knows their Plan, and HR gets its week back. Being there for everyone during open enrollment is a staffing decision you make in September.
Open enrollment goes better when the prep is boring. If you’d rather not build the checklist, the notice calendar, and the contribution model from scratch, talk to Totem. We’ll tell you what we’d do first.
Frequently asked questions
When should open enrollment preparation start?
Work backward from the day enrollment materials go out. Under 29 CFR 2590.715-2715, the Summary of Benefits and Coverage is distributed with written enrollment application materials, so Plan design, contributions, and the SBC have to be final before that date.
What is the 2027 HSA contribution limit?
For 2027, Revenue Procedure 2026-24 sets the HSA contribution limit at $4,500 for self-only coverage and $9,000 for family coverage. The same guidance sets the HDHP minimum annual deductible at $1,750 self-only and $3,500 family.
When are Medicare Part D creditable coverage notices due?
CMS requires a written disclosure notice to all Medicare eligible individuals covered under the prescription drug plan prior to October 15 each year. That includes active employees, COBRA participants, disabled individuals, retirees, and their dependents.
Does a self-funded employer’s checklist look different?
The notices and the statutory limits are the same. The contribution model isn’t. A self-funded employer sets rates against fixed costs, expected claims, and stop loss premium, so funding and contributions are one conversation.
This post explains federal requirements in general terms. It isn’t legal, tax, or fiduciary advice. Talk to your Totem consultant or counsel about how any of it applies to your Plan.
