This article is for admins who manage health benefits through Gusto or the broker integration.
Changing your medical plan renewal date to January 1 is a significant decision with specific compliance requirements and potential impacts on your team. This guide helps you understand the eligibility requirements, implications, and administrative considerations before making this change.
Your company must meet all of the following criteria to change your medical plan renewal date to January 1. There are no exceptions due to federal compliance and carrier regulations.
Current renewal date – Your medical plan renewal date must not currently be January 1.
Carrier underwriting approval: While every carrier is different, they typically review several factors before deciding whether to grant an exception. Carriers look at your company's specific profile to see if a mid-year shift is a fit for their current business rules.
No active tax-advantaged accounts – Your company cannot have an active Health Savings Account (HSA), Flexible Spending Account (FSA), or Dependent Care FSA (DCFSA). Adjusting these policy periods mid-year is not compliant. (Commuter benefits are allowed because they are not tied to health renewal.)
Plan type – Companies with level-funded plans cannot change their renewal date. Carriers do not allow renewal date changes due to the way those specific contracts are structured.
Who decides if the change is approved?
Approval is entirely at the discretion of your insurance carrier. Each carrier has its own set of underwriting rules and deadlines for when they will allow a company to shift their renewal date.
Since the carrier makes the final call on a case-by-case basis, our team of licensed advisors is here to help you navigate the uncertainty. We will review your specific carrier’s rules, check for any potential compliance issues, and guide you through the request based on what the carrier allows within their strict timeframes.
While the decision is yours to make, we encourage you to weigh these disruptions against your current plan structure. Most companies find that staying on their current cycle avoids significant employee dissatisfaction and administrative friction.
The most significant risk of changing your renewal date is the reset of employee deductibles. Most insurance carriers do not carry over amounts employees have already paid toward their deductibles or out-of-pocket maximums during a mid-year shift. Your team members would start over at $0 on January 1.
Premium increases
Premiums are determined by carriers quarterly and increase consistently. Both employers and employees will be affected by the increase when moving to a January 1 renewal.
Open enrollment
You will conduct two full open enrollments in one year when you change your renewal date.
Plan misalignment
Changing your medical renewal does not change your ancillary plans like dental, vision, and life insurance. Moving forward, you will manage two separate renewals and two separate open enrollment periods every year.
Shortened timelines
Due to strict year-end carrier deadlines, the January 1 open enrollment window is shortened to just three business days instead of the standard 7–10 day window.
January 1 is the busiest time for the insurance industry. This leads to several challenges.
Late plan and rate availability
Carriers are slower to release January 1 rates, giving you less time to make decisions.
Extended response times
Gusto's dedicated advisors assist the largest portion of renewal customers for January 1 effective dates. As a result, response times may be longer, and availability to discuss plans and renewal options could be limited within the compressed timeframe.
Retroactive approvals
Coverage is often approved retroactively, in late January. Team members may have to pay for services out-of-pocket and submit claims for reimbursement later.
Review the table below to compare how your current renewal differs from a January 1 shift.
Feature
Standard renewal
January 1 shift
Open enrollment
Once per year
Twice in the first year
Enrollment window
Standard 7–10 day window
Shortened 3-day window due to carrier deadlines
Deductible progress
Accumulates for a full 12 months
Resets to $0 on January 1
Premium rates
Locked in for your full 12-month cycle
Immediate reset to new quarterly rates
Plan alignment
Medical and ancillary plans stay aligned
Plan misalignment creates multiple renewals per year, requiring additional open enrollments for other lines of coverage
Carrier stability
Faster processing and ID card delivery
High risk of coverage not being approved until after the effective date
If you’d like to explore changing your renewal date, contact us from the help icon
in your Gusto account. We can only accept requests between mid-August through September due to the carrier deadlines and volume during peak season. We cannot process requests outside of this window so we recommend contacting us early so your request can be reviewed in time. A licensed benefits advisor will review your benefits, confirm eligibility, and guide you through the next steps.