Update On Premium Subsidy For COBRA & State Continuation

 
Model Notices

The American Recovery and Reinvestment Act ['"Stimulus Act"]  has directed the Department Of Labor [DOL] to provide model notices for employers, allowing them to provide information to individuals about the Premium Subsidy provisions. These model notices were released on March 19, 2009.

 

Reduction in Hours Eligibility

A COBRA trigger or qualifying event is one that results in the loss of group coverage. Thus, an individual [and eligible covered dependents] that loses group coverage because of a reduction in hours is eligible for COBRA. HOWEVER, it appears that reduction in hours, even when involuntary, does not qualify an individual for the COBRA Premium Subsidy.

 

In most instances, the employer determines the number of hours that an individual needs to work to qualify for benefits, including group health coverage. In Ohio, the number of hours required for benefit eligibility is spelled out in law:

"Eligible employee" means an employee who works a normal work week of twenty-five or more hours.

"Eligible employee" does not include a temporary or substitute employee, or a seasonal employee who works only part of the calendar year on the basis of natural or suitable times or circumstances. [Emphasis added. Please see Ohio Revised Code Section 3924.01(G)]

 

Mail Merge Template Of Model Premium Subsidy Notice 
April 3, 2009 HORAN will offer a mail merge template[s] of the model notice[s] to all clients.  The template will work in the same way as our Medicare Part D templates and will include detailed instructions on how to use.