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August 3, 2026

Compliance Q&A: Retroactive Termination of Individuals’ Benefits Coverage

Benefits administrators are only human, and with the increased complexity and the number of moving pieces involved in updating health plan eligibility, it’s possible for plan terminations to occasionally be missed. This Q&A details the compliance considerations involved in correcting those mistakes, including the Affordable Care Act’s prohibition on rescissions of coverage (termination of coverage that has a retroactive effect) and COBRA implications where applicable.