We do retroactive health plan terminations as part of our monthly record-keeping. Is that considered a rescission?

No. The Department of Health and Human Services has clarified that retroactive cancellations of health insurance done in the normal course of business are not rescissions. Instead, groups may apply terminations retroactively if they are based on a delay in administrative record-keeping. For example, if your human resources department only reconciles eligibility based on monthly data feeds, then terminations done as a result of such reconciliation may be allowed. For more information on recessions, please see this fact sheet.