New CHIP Model Notice Released by DOL for 2025

A new Children’s Health Insurance Plan (CHIP) Notice has just been issued by the Department of Labor (DOL), reflecting updated information which brings it current to March 17, 2025.

For background, the Children’s Health Insurance Program Reauthorization Act of 2009 (CHIPRA) implemented an annual notice requirement for any employers that maintain a group health plan that covers participants who reside in a state that provides any type of premium assistance subsidies under a CHIP or Medicaid plan. The notice obligation does not depend on the employer’s physical location(s) and is based instead on where the plan’s eligible individuals reside.

The DOL makes annual updates to the CHIP Notice for states offering premium assistance subsidies, editing items such as addresses, phone numbers, correcting typos, and editing any other pertinent information. In a side-by-side comparison to the previous iteration of the Notice, you will note no material changes to this version, which is unusual for CHIP, as we’ve come to expect certain state-by-state nuances with each update.

Employers are not required to use the DOL’s version of the CHIP Notice, and in many instances may instead decide to create their own if they want to highlight only the pertinent states to the individuals on their plans, update the graphics, add their own branding, etc.

Employers are also not restricted by the way in which they choose to distribute the CHIP Notice, so long as it is received by all employees who currently are or might become eligible for the group health plan and who also reside in a state that provides premium subsidies through the CHIP or Medicaid programs listed on the Notice. While many employers opt to distribute the Notice during open enrollment or in their benefit guides or Wrap Plan SPD, the goal here is to ensure that all employees who receive a W-2 from the employer also receive the CHIP Notice. Whichever method is deployed, distribution of the CHIP Notice is an annual requirement and must be completed immediately for all new hires as well.

Additional Links:
• Fact Sheet
• Federal Register