Q: Open enrollment for the 2026 plan year has closed, and an employee wants to change his election before the new year starts. Can we allow the change?
A: Usually no, but there is one important exception.
Employees generally cannot change their elections after open enrollment closes unless they experience a permitted IRS Section 125 qualifying life event. The fact that the new plan year has not started does not allow changes.
However, there is one exception. If the employee made a mistake of fact when making the election, the employer may correct it before the new plan year begins. A mistake of fact is an unintentional error, such as selecting the wrong coverage tier, choosing the wrong dependent, or misunderstanding which plan was selected. The employer must be able to reasonably determine that the election was made in error and that the correction aligns with the employee’s intent.
You typically cannot allow changes based on preference shifts or second thoughts.
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This article is for informational purposes only and is not intended as legal, tax, or benefits advice. Readers should not rely on this information for taking (or not taking) any action relating to employment, compliance, or benefits. Always consult with a qualified professional before making decisions based on this content.