Employees on Leave During Open Enrollment
What Employers Need to Know
Open enrollment communication usually focuses on employees who are actively working and checking their email, attending benefits meetings, and logging into the enrollment system.
But what about the employee who is out on leave?
Employees on a leave of absence can easily become an overlooked part of the open enrollment process. Depending on the type of leave, the employer's benefit plans, and applicable law, questions may arise about enrollment access, benefit continuation, premium payments, deadlines, and what happens when the employee returns.
That's why leave administration should be part of open enrollment planning—not something employers address after a problem occurs.
A strong process helps employers coordinate benefits more consistently while making sure employees on leave receive the information they need.
Why Leave Should Be Part of Your Open Enrollment Planning
A leave of absence may be paid or unpaid and may arise for many reasons. Depending on the circumstances, leave may involve federal or state leave protections, military service, disability or accommodation considerations, an employer-provided leave program, or another approved absence.
Examples may include FMLA leave, military leave, disability-related leave or accommodation, parental leave, and personal leave under an employer's policy.
The important point for open enrollment is this:
An employee being away from work does not mean the employer should simply remove that employee from the open enrollment process.
The employee's rights, eligibility, coverage, and payment obligations can depend on the applicable law, plan documents, type of leave, and employer policy.
HR TIP Before open enrollment begins, identify employees who are currently on leave or are expected to remain on leave during the enrollment window. Then determine how communications, elections, deadlines, and benefit administration will be handled for each situation. |
1. Determine How Employees on Leave Will Receive Open Enrollment Information
Employees who are actively working may receive open enrollment information through company email, staff meetings, an HRIS, or workplace announcements.
An employee on leave may not have the same access.
Before enrollment opens, employers should determine how employees on leave will receive applicable enrollment materials and instructions.
Consider:
Does the employee still have access to company email?
Can the employee access the benefits enrollment system remotely?
Is an alternate personal email or mailing address available for appropriate benefits communication?
Who is responsible for communicating with employees on leave?
How will the organization document that enrollment information was provided?
The goal is to avoid discovering after the enrollment deadline that an employee never received the information needed to participate.
2. Review Benefit Eligibility and Coverage During Leave
Benefit continuation during a leave of absence can vary.
The answer may depend on the type of leave, applicable law, the employer's plan documents, insurance carrier rules, and the organization's leave policies.
For example, eligible employees taking qualifying FMLA leave generally have specific protections related to continuation of group health coverage during FMLA leave, subject to applicable requirements.
Other types of leave may be handled differently.
Employers should avoid relying on assumptions such as:
“They're still an employee, so benefits automatically continue.”
or
“They're unpaid, so benefits automatically stop.”
Instead, verify how the applicable plan and leave rules work before communicating with the employee.
COMPLIANCE REMINDER Benefits and leave can involve multiple rules at the same time. Coordinate with your benefits broker, carrier, plan administrator, HR professional, or legal counsel when determining how coverage should be handled in a specific leave situation. |
3. Decide How Benefit Premiums Will Be Handled
One of the most common administrative challenges occurs when an employee's normal payroll deductions are interrupted.
If an employee is on unpaid leave—or does not receive enough wages to cover normal deductions—the organization needs a process for determining how the employee's required share of benefit premiums will be collected, where applicable.
Questions to address may include:
Will premiums continue through payroll when wages are available?
Is direct payment required during unpaid leave?
When are payments due?
How will employees receive payment instructions?
Who will monitor outstanding amounts?
What happens when the employee returns to work?
How will any permitted catch-up deductions be coordinated with payroll?
The process should be based on applicable law, plan terms, and established employer procedures—not created differently for each employee as situations arise.
4. Don't Confuse Open Enrollment With Mid-Year Election Changes
Open enrollment and mid-year benefit election changes are related, but they are not the same process.
Open enrollment is the employer's designated annual election period.
Outside that period, certain benefit elections may be changed only when permitted by the applicable plan and rules, including circumstances involving qualifying events or other permitted changes.
A leave of absence does not automatically mean every employee can make any benefit change they want outside open enrollment.
Likewise, an employee may experience another event while on leave—such as marriage, birth, adoption, or another qualifying circumstance—that could affect available election rights.
Employers should coordinate these situations with the applicable plan administrator or benefits advisor and follow the plan's rules and deadlines.
5. Make Sure Leave and Benefits Communications Are Consistent
Leave administration often involves multiple people or systems.
✓ A manager may know the employee is out.
✓ HR may be managing the leave.
✓ Payroll may need to change deductions.
✓ The benefits broker or carrier may be managing coverage information.
✓ And the employee may be receiving communications from several different sources.
Without coordination, inconsistent information can easily be communicated.
Create a clear internal process for determining:
WHO manages the leave
WHO manages benefit eligibility questions
WHO communicates open enrollment information
WHO coordinates premium payments
WHO communicates payroll changes
WHO documents employee elections and follow-up
Clear ownership reduces the risk of important steps falling between departments or vendors.
6. Think About the Employee's Return From Leave
Open enrollment planning should also consider what happens when the employee returns.
Depending on the circumstances, employers may need to verify benefit elections, payroll deductions, coverage status, outstanding premium matters, or other administrative items.
A simple return-from-leave benefits review can help identify discrepancies before they continue across multiple payrolls or create confusion for the employee.
Consider confirming:
✓ Current benefit elections
✓ Coverage effective dates
✓ Payroll deductions
✓ Any outstanding employee premium obligations, where applicable
✓ Changes that occurred while the employee was away
✓ Any required benefits or payroll follow-up
7. Protect Employee Privacy
Leave situations may involve sensitive medical or personal information.
Open enrollment does not change the employer's responsibility to handle confidential employee information appropriately.
Managers generally do not need detailed medical information simply because an employee is on leave.
Benefits and leave communications should be handled through appropriate channels, and access to confidential information should be limited based on business need and applicable requirements.
Build Employees on Leave Into Your Open Enrollment Checklist
Instead of waiting until open enrollment begins, add a leave review to your pre-enrollment process.
Before Open Enrollment
Identify employees who are currently on leave or expected to be on leave during enrollment.
Review applicable leave policies and benefit plan provisions.
Confirm how each employee will receive enrollment information.
Determine whether payroll deductions will continue or another premium-payment process may be needed.
Clarify internal ownership among HR, payroll, benefits vendors, and managers.
During Open Enrollment
Provide applicable enrollment materials and deadlines.
Confirm access to the enrollment system or provide an appropriate alternative process.
Document important communications and employee elections.
Coordinate questions involving leave status, eligibility, or benefit continuation with the appropriate advisor or administrator.
Track unresolved issues before enrollment closes.
After Open Enrollment
Confirm elections were processed.
Coordinate applicable carrier and payroll updates.
Review deductions when the employee is receiving wages.
Track unresolved premium or coverage issues.
Include benefits verification in the employee's return-from-leave process when appropriate.
Technology Helps—but It Doesn't Replace a Process
HRIS and benefits systems can make open enrollment and leave administration easier by centralizing information, sending reminders, tracking elections, and supporting documentation.
But technology alone won't determine:
Who should contact an employee on leave.
Whether a particular benefit continues.
How an unpaid premium should be handled.
Whether a mid-year election change is permitted.
Or who should follow up when information doesn't match.
Those decisions still require clear processes, defined ownership, and coordination among the people responsible for HR, payroll, benefits, and leave administration.
Final Thoughts
Employees on leave should not become an afterthought during open enrollment.
When employers prepare early, they can identify employees who may need a different communication or administrative process and coordinate the details before deadlines begin approaching.
The goal is not to create a separate open enrollment program for employees on leave.
It's to make sure your existing process accounts for them.
Review the leave.
Review the plan.
Clarify responsibilities.
Communicate appropriately.
Document what happened.
And verify that benefits and payroll are aligned.
Those steps can make open enrollment smoother for the organization and the employee—especially when leave and benefits intersect.
Need Help Strengthening Your Open Enrollment Process?
Ahrise Consultant Group helps small businesses, nonprofits, and growing organizations strengthen the HR processes behind benefits and leave administration. From open enrollment planning and employee communication to leave coordination, HR systems, payroll alignment, and benefits administration support, we help employers build clearer and more consistent HR processes. Visit our store to check out some compliance resources that can help your business |
This article is provided for general informational purposes and is not legal advice. Employment requirements may vary based on jurisdiction and individual circumstances.
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