12.1 Group Health Fundamentals and Eligibility
Key Takeaways
- The employer holds the single master policy; each covered employee receives a certificate of coverage, which summarizes benefits but is not the contract itself.
- Group underwriting evaluates the group as a whole, not individuals, so most enrollees get guaranteed-issue coverage with no medical exam.
- A probationary (waiting) period delays new-hire eligibility; the actively-at-work provision requires the employee to be working on the effective date.
- An eligible dependent typically includes a spouse and children up to age 26 under the ACA, regardless of student or marital status.
- Eligibility rules, minimum participation, and active-work requirements all exist to control adverse selection.
Group health insurance covers a defined group of people, most often the employees of a single employer, under one contract. The exam tests how group coverage differs structurally from individual coverage, who qualifies, and which rules exist to stop only sick people from enrolling.
The Master Policy and Certificates
The insurer issues one master policy to the employer, who is the policyholder. Each covered employee receives a certificate of insurance that summarizes benefits, exclusions, and claim procedures.
| Document | Held By | Legal Status |
|---|---|---|
| Master policy | Employer (policyholder) | The actual contract |
| Certificate | Each employee | Proof/summary of coverage, NOT the contract |
A common trap: if a benefit in the certificate conflicts with the master policy, the master policy controls, because it is the contract. Employees are the insureds, not policyholders.
Group vs. Individual Underwriting
Group underwriting evaluates the group as a whole, examining its size, industry hazard, age and gender mix, geography, and prior claims experience. It does not normally require individual medical exams.
| Factor | Group Health | Individual Health |
|---|---|---|
| Unit underwritten | Entire group | Single applicant |
| Medical exam | Usually none | Often required |
| Issue basis | Guaranteed issue (most) | Underwritten |
| Adverse-selection control | Eligibility rules | Underwriting |
Eligibility and Waiting Periods
To be eligible, a person must usually be a full-time employee (30+ hours/week under the ACA) in an eligible class. Two timing rules matter:
- Probationary (waiting) period - a delay (commonly 0-90 days; ACA caps it at 90) before a new hire may enroll.
- Eligibility/enrollment period - the window (often 31 days) to elect coverage after becoming eligible; missing it may require waiting for open enrollment or proving insurability.
The Actively-at-Work Provision
The actively-at-work provision requires the employee to be performing normal job duties on the date coverage takes effect. If the employee is home sick on the effective date, coverage may be deferred until they return to work. This prevents someone from enrolling specifically because they are already disabled.
Eligible Dependents
Under the ACA, plans offering dependent coverage must extend it to children up to age 26, regardless of student status, marital status, or financial dependency. A spouse is typically eligible; in many states a domestic partner may be added.
Exam trap: a 24-year-old, married, non-student child is STILL an eligible dependent under the federal age-26 rule.
Open Enrollment vs. Special Enrollment
Group plans set an annual open enrollment window during which any eligible employee may join or change elections without proving insurability. Outside that window, coverage changes require a special enrollment period triggered by a qualifying life event.
| Special-Enrollment Trigger | Typical Window |
|---|---|
| Marriage, birth, or adoption | 30 days |
| Loss of other coverage | 30-60 days |
| Gaining a dependent | 30 days |
Without a qualifying event, an employee who declined coverage and later wants in must wait for open enrollment. This rule, like the participation thresholds, exists to stop employees from waiting until they are sick to enroll.
Classes of Eligible Employees
An employer may define eligible classes by objective, non-discriminatory criteria such as full-time status, job category, or length of service. It may NOT define classes to favor only healthy or highly compensated individuals, because HIPAA bars eligibility rules based on health status. A part-time worker below the hours threshold is simply not in an eligible class, which is different from being declined for health reasons.
Coordination of Benefits Preview
When a person is covered by more than one group plan, a coordination of benefits (COB) provision decides which plan pays first (the primary plan) and which pays the balance (the secondary plan). For an employee, their own employer's plan is primary.
For a dependent child covered under both parents, the birthday rule makes primary the plan of the parent whose birthday falls earlier in the calendar year. The combined payment never exceeds 100% of the allowable charge, so COB prevents over-insurance and duplicate recovery.
Eligibility, Enrollment Periods, and the Master Contract
Group health is issued under a master contract to the employer; employees receive a certificate of coverage. To be eligible an employee generally must be full-time and actively at work and have satisfied any probationary period (commonly up to 90 days under the ACA limit). Enrollment is restricted to defined windows:
- Initial enrollment period — when first eligible.
- Open enrollment — an annual window to join or change plans without evidence of insurability.
- Special enrollment — triggered by qualifying life events (marriage, birth, loss of other coverage), typically within 30 days.
Exam trap: An employee who declines coverage at initial eligibility and has no qualifying event generally must wait for open enrollment and may face evidence of insurability as a late entrant — the mechanism that controls adverse selection in contributory plans.
Why Group Underwriting Differs
Group coverage underwrites the group as a unit, not each person, so most enrollees obtain coverage with no individual medical exam up to a guaranteed-issue limit. The insurer evaluates the group's size, industry, claims experience, and demographics. This pooling is exactly why group coverage is cheaper and more accessible than individual coverage — and why minimum participation rules exist to keep the pool from filling only with high-risk members.
In a group health plan, which statement about the master policy and certificates is correct?
An employee is approved for group coverage with a January 1 effective date but is home recovering from surgery and not working on January 1. Which provision most likely delays the start of coverage?