Benefits brokers managing annual compliance packets for employer clients have a task to add to the checklist. The US Department of Labor (DOL) has released an updated model Premium Assistance Under Medicaid and the Children's Health Insurance Program Notice, known as the CHIP Notice, with a revised state list current as of July 31.
The update does not require employers to reissue the notice to employees who already received the current plan year version. For any future distributions, including new hire onboarding, special enrollment events, and open enrollment packets, employers should use the updated model.
The CHIP Notice is a federally mandated annual disclosure under the Children's Health Insurance Program Reauthorization Act (CHIPRA). Employers that offer a group health plan in a state that provides Medicaid or CHIP premium assistance must deliver the notice to employees in those states, free of charge, on an annual basis.
The updated model, issued by the DOL's Employee Benefits Security Administration (EBSA), reflects changes in state program availability as of July 31. It carries a stated expiration date of May 31, 2029. EBSA typically updates the model notice twice per year, so a further revision is likely before that date.
Employers that operate across multiple states face a practical decision. They can track employee state of residence and distribute only to those in qualifying states, or send the notice to all employees. The DOL permits the broader approach. Many employers treat it as the simpler path for large, multi-state workforces.
Brokers who prepare or distribute annual notices packets on behalf of employer clients should replace any stored CHIP Notice templates with the updated version. The notice may be included alongside other annual compliance materials, provided it is visually separated from those materials.
The updated model is available in English and Spanish on the EBSA website.
For employers that have already distributed a CHIP Notice for the current plan year, no further action is required for that cycle. The updated model applies to any distribution that has not yet taken place. That includes open enrollment packets being assembled in the coming weeks.
The CHIP Notice may be delivered alongside other materials, including a summary plan description or annual notices packet. It must be visually separated from those documents, not buried within them.
Electronic delivery is permitted under existing DOL rules where employees have regular work-related computer access or have consented to electronic delivery. The obligation applies to employers whose plans cover employees in states with qualifying Medicaid or CHIP premium assistance programs. Broader distribution to all employees is also permitted.
Brokers and HR teams assembling open enrollment materials should confirm the updated version is in use across all distribution channels before packets go out.
