Please be advised that the COBRA subsidy program has been extended through 5/13/2010. This is the third extension through the Continuing Extension Act of 2010.
Special Election Period
A health plan must extend a special COBRA election period to an individual who experienced an involuntary termination of employment on or after April 1, 2010, and prior to April 15, 2010, and who would be an “assistance eligible individual” (AEI) but who does not have a COBRA election in effect on April 15, 2010. The special election period runs from April 15, 2010, through 60 days after the Notice of Special Election Period is provided to that individual.
Notice of Special Election Period
In the case of any individual who experienced a qualifying event related to a termination of employment between April 1, 2010 and April 15, 2010, an employer must provide the general COBRA notice, including a description of the availability of premium reduction in the case of a qualifying event that is an involuntary termination of employment, within 60 days of enactment of the Act or by June 14, 2010. If the general COBRA notice was already distributed, then employers may simply supplement it with an additional notice describing the extension of the availability of premium reduction with respect to involuntary terminations through May 31, 2010, and the special election period.
A Reminder – Expansion of Assistance Eligible Individuals
Under previous legislation, only individuals who experienced a qualifying event that was an employee’s involuntary termination of employment could become AEIs and take advantage of the COBRA premium subsidy. The Temporary Extension Act of 2010 expanded the premium subsidy to include as a qualifying event for purposes of the subsidy, a reduction of hours that occurred at any time on or after September 1, 2008, and is followed by an involun¬tary termination of employment that occurs on or after March 2, 2010 (and before June 1, 2010). Individuals who experience a qualifying event that falls under this expanded definition and are otherwise eligible AEIs will be eligible for the COBRA subsidy beginning with the first day of the first period of coverage for which the individual is affected.
Action Items
>>Notices. Employers should update their COBRA notices and other plan communications to include the extension of the eligibility period to May 31, 2010.
>>Assess Prior Terminations. Identify covered employees (and their qualified beneficiaries) who became eligible for COBRA on or after April 1, 2010, and before April 15, 2010, as well as their COBRA elections. Provide an updated COBRA notice to these individuals that includes a description of the extended eligibility period and the special election period. Identify those employees and beneficiaries in the group whose qualifying event is the employee’s involuntary termination of employment and who are eligible for the COBRA subsidy.
Showing posts with label extension. Show all posts
Showing posts with label extension. Show all posts
Monday, April 26, 2010
Friday, March 12, 2010
Additional COBRA Subsidy Extension - 2010
On March 2, 2010, President Obama signed the Temporary Extension Act of 2010 (H.R. 4691), which extends the eligibility period for the COBRA premium subsidy through March 31, 2010. The eligibility period, as previously extended by the Department of Defense Appropriations Act, 2010 (P.L. 111-118), had expired on February 28, 2010.
The law also expands the definition of "assistance eligible individual" to include as a qualifying event the loss of health care coverage because of a reduction in hours followed by involuntary termination of employment. The Act provides that individuals who had a reduction of hours between September 1, 2008 and March 31, 2010, followed by an involuntary termination of employment on or after March 2, 2010, shall be treated as incurring a qualifying event on the date of termination of employment. As a result, these individuals will be eligible for the COBRA subsidy. The period of COBRA continuation coverage, however, is determined as though the qualifying event was the reduction of hours. Group health plans must notify affected individuals within sixty (60) days following their termination of employment of their right to the COBRA subsidy.
The Temporary Extension Act also provides short-term extensions of several authorities, including those related to unemployment compensation, Medicare physician payments, Medicare therapy caps, surface transportation programs, flood insurance programs, retransmission of television broadcasts, Federal poverty guidelines, and Small Business Administration loan guarantees.
The law also expands the definition of "assistance eligible individual" to include as a qualifying event the loss of health care coverage because of a reduction in hours followed by involuntary termination of employment. The Act provides that individuals who had a reduction of hours between September 1, 2008 and March 31, 2010, followed by an involuntary termination of employment on or after March 2, 2010, shall be treated as incurring a qualifying event on the date of termination of employment. As a result, these individuals will be eligible for the COBRA subsidy. The period of COBRA continuation coverage, however, is determined as though the qualifying event was the reduction of hours. Group health plans must notify affected individuals within sixty (60) days following their termination of employment of their right to the COBRA subsidy.
The Temporary Extension Act also provides short-term extensions of several authorities, including those related to unemployment compensation, Medicare physician payments, Medicare therapy caps, surface transportation programs, flood insurance programs, retransmission of television broadcasts, Federal poverty guidelines, and Small Business Administration loan guarantees.
Thursday, December 24, 2009
COBRA Subsidy Extended
The American Recovery and Reinvestment Act of 2009 (ARRA), commonly known as the federal economic stimulus bill, passed earlier this year, required companies to provide a COBRA subsidy for up to 9 months. The ARRA also requires employers to pay 65% of the group health care insurance plan premiums for COBRA assistance eligible employees who were involuntarily terminated from employment between September 1, 2008 and December 31, 2009. Eligible individuals pay only 35% of their COBRA premiums. The employer may recover the 65% premium subsidy by taking a credit on its quarterly federal employment tax return. Certain high-income individuals may have to repay all or part of the premium subsidy through an increase in their income tax liability for the year. Subsidy eligibility ends when the individuals are eligible for coverage under another group medical insurance plan or Medicare, or the normal period for COBRA eligibility ends. Employees terminated for cause may not be assistance eligible. By now, employers or their COBRA administrators have amended their COBRA notices and practices to be ARRA compliant.
On December 19, 2009, President Obama signed into law H.R. 3326, the Department of Defense Appropriations Act, 2010 (Act). The Act immediately amends the ARRA by extending the COBRA subsidy period from 9 to 15 months and extending the cut-off for commencement of the subsidy period from December 31, 2009 to February 28, 2010.
Employers or their COBRA administrators must now update their COBRA eligibility and election notices to include the extended subsidy information. In addition, within 60 days of enactment of the Act, special notice must be given to any COBRA assistance eligible individual who was either already on COBRA on or after October 31, 2009 or was involuntarily terminated on or after October 31, 2009 who already received a COBRA rights notice that did not include the subsidy extension information.
According to the U.S. Department of Labor’s (DOL) press release, individuals who had reached the end of the reduced premium period before the legislation extended it to 15 months will have additional time to pay the reduced premiums related to the extension. To continue their coverage they must pay the 35% of premium costs by “60 days after date of enactment” or, if later, 30 days after notice of the extension is provided by their plan administrator.
On December 19, 2009, President Obama signed into law H.R. 3326, the Department of Defense Appropriations Act, 2010 (Act). The Act immediately amends the ARRA by extending the COBRA subsidy period from 9 to 15 months and extending the cut-off for commencement of the subsidy period from December 31, 2009 to February 28, 2010.
Employers or their COBRA administrators must now update their COBRA eligibility and election notices to include the extended subsidy information. In addition, within 60 days of enactment of the Act, special notice must be given to any COBRA assistance eligible individual who was either already on COBRA on or after October 31, 2009 or was involuntarily terminated on or after October 31, 2009 who already received a COBRA rights notice that did not include the subsidy extension information.
According to the U.S. Department of Labor’s (DOL) press release, individuals who had reached the end of the reduced premium period before the legislation extended it to 15 months will have additional time to pay the reduced premiums related to the extension. To continue their coverage they must pay the 35% of premium costs by “60 days after date of enactment” or, if later, 30 days after notice of the extension is provided by their plan administrator.
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